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2014 (7) TMI 1067 - AT - Income TaxAddition u/s 40(a)(i) r.w section 195 - Commission paid to non-resident – Held that:- As per Circular No. 786 dated 07.02.2000 for non deduction of TDS, the Assessee was not required to deduct TDS u/s. 195 with regard to payment of commission to foreign agents - assessee had filed the return of income in accordance with the circular prevailing at that time – Relying upon Dy. CIT v. Panchmahal Steel Ltd. [2010 (8) TMI 875 - ITAT AHMEDABAD] - there was no default on the part of the assessee not to deduct TDS in such circumstances based upon its opinion on the CBDT circulars - no disallowance can be made – Decided in favour of Assessee.
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