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2018 (4) TMI 1564 - AT - Income TaxTDS u/s 195 - income accrued in India - receipt in India of the sale proceeds of tobacco - Held that:- In the instant case, the non-resident assessee did not carry on any business operations in the taxable territories. They acted as selling agents outside India. The receipt in India of the sale proceeds of tobacco remitted or caused to be remitted by the purchasers from abroad does not amount to an operation carried out by the assessee in India as contemplated by cl. (a) of the Explanation to s. 9(1)(i) of the Act. The commission amounts which were earned by the nonresident assessee for services rendered outside India cannot, therefore, be deemed to be incomes which have either accrued or arisen in India.
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