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2017 (4) TMI 869 - AT - Income TaxTDS u/s 195 - payment made to KPMG International, Switzerland without TDS - principle of Mutuality application - Indian-Switzerland tax treaty - Held that:- There is a complete identity between the contributors and participators; the actions of the participators and contributors are in furtherance of the mandate of the association. There seems be no element of profit by the contributors from a fund made by them, which could only be expended or returned to themselves. Based on these conditions case of the assessee falls within the four corner of the ambit of the ‘Principle of Mutuality’. Thus, we do not find any reason or ground to interfere in the order passed by learned Commissioner (Appeals) hence the appeal filed by the revenue is dismissed.
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