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2021 (6) TMI 1081 - HC - Income TaxTDS u/s 195 - disallowance u/s 40(a)(ia) on commission payments made to non residents agents - whether said services are not in the nature of technical services and does not come under purview of section 9(2) of the Act ? - HELD THAT:- As decided in M/S. PUMA SPORTS INDIA P., LTD., [2021 (4) TMI 93 - KARNATAKA HIGH COURT] this Court is of the considered opinion that in the present case the Associated Enterprises has rendered services out of India in the form of placing orders with the manufacturers who are already outside India. The commission was paid to Associate Enterprises out of India. No taxing event has taken place within the territories of India and therefore, the Tribunal was justified in allowing the appeal of the assessee.
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