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2008 (9) TMI 596 - AT - Income TaxDisallowance - Under section 40(a)(i) - Commission - deduct the tax at source under section 195 - No income accrued to the assessee in India inasmuch as the services were rendered outside India and the payment was made outside India - It was also submitted that a non-resident had no establishment in India and therefore, no tax was payable in view of the Indo-UK Treaty - The learned CIT(A) accepted the contention of the assessee and consequently deleted the disallowance made by the Assessing Officer - Decided in favour of assessee.
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