2024 (10) TMI 354

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.... ORDER PER BENCH These appeals filed by the assessee are directed against separate orders of the National Faceless Appeal Centre, Delhi [CIT(A)] dated 31.01.2023 & 01.02.2023 for Assessment Years (AY)2010-11& 2013-14 respectively. First, we take-up ITA No. 231/Coch/2023 for the AY 2010-11 2. The only issue raised by the assessee in these appeals is that the learned CIT(A) erred in conf....

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....hdrawn on October 23, 2009, and since the appellant had already made the payment amounting to Rs. 8,08,886/- to M/s Grecal Ltd., the A.O. has only made the addition of Rs. 4,26,849/- as that was paid after the withdrawal of the circular. Also, it is important to mention the AAR decision of M/s SKF Boiler and Drivers Pvt. Ltd. dated February 22, 2012. In the decision, it is clearly held that althou....

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.... commission paid to overseas agents was deemed to accrue or arise in India and was accordingly taxable under the provision of section 5(2)(b) r.w.s. 9(1)(i) of the Act but the assessee has failed to make the compliances with the provisions of section 195(2) of the Act. In this case, the non-residents agents have rendered their services outside India in connection with procurement of sale. All the ....