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2009 (7) TMI 58 - AUTHORITY FOR ADVANCE RULINGSMarketing and Promotion of Business - Issue of existence of P/E in India and Deduction of TDS - Services were being rendered outside India - No office in India - Commission is received out of sale proceeds for every completed transaction - no office establishment maintained in India - Held that amount paid on account of the commission paid to it by the applicant is not chargeable to tax in India by virtue of Art. 7 of DTAA and Section 9(1)(i) read with the Explanation thereto, the applicant is not obliged to deduct the tax at source under Section 195 of the Income-tax Act 1961.
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