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2019 (3) TMI 1969 - ITAT DELHITDS u/s 195 - non-deduction of TDS on the payment made to foreign entity in USA and Italy (SPA) holding the same as commission - whether such payments made was in the nature of commission or fee for technical services and the assessee only named the same as commission - HELD THAT:- DR though relied on the orders of the Assessing Officer, but did not object to the contention of the learned AR that the issue involved in both these appeals are squarely covered by the decision of Co-ordinate Bench in assessee's own case for A.Y. 2010-11 [2019 (1) TMI 537 - ITAT DELHI] whereby in the identical facts of the case, the payments made to the same agents have been treated as commission and not as fee for technical services - Decided against revenue.
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