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2015 (3) TMI 189 - AT - Income TaxNon-deduction of TDS on the agency commission paid to non-resident agents - CIT(A) deleted the disallowance u/s 40(a)(i) - Held that:- TDS is required to be deducted on all payments to non-residents if the said payments are liable for tax in India. In the instant case, the commission payments to the non-resident agents are not taxable in India as the services are rendered abroad and the agents have no PE in India. Therefore, there is no requirement to deduct TDS on these payments. See GE India Technology Cen. P Ltd. v. CIT 2010 (9) TMI 7 - SUPREME COURT OF INDIA ) - Decided in favour of assessee.
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