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2014 (4) TMI 1092 - AT - Income TaxDisallowance u/s 40(a)(ia) - disallowance of commission paid of foreign agent and late payment of interest to the same agent - Held that:- When the assessee’s status of non-resident was not in dispute and that the assessee had given the copy of the agreement, details of the services rendered, correspondence for services availed alongwith supporting evidence, and moreover at that relevant time when the TDS was required to be deducted, the said CBDT circular no. 786 [F No. 500/108/98-FTD] dated 07.02.2000 [Withdrawn by Circular No. 7/2009 [F. No. 500/135/2007-FTD-I] was in operation, we hereby hold that the invocation of the provisions of section 40(a)(ia) read with section 195(2) was incorrect. The findings of the authorities below are hereby reversed and this ground of appeal of assessee is allowed. - Decided in favour of assessee
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