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2019 (7) TMI 1978 - AT - Income TaxTDS u/s 195 - payments made to non-resident professionals - Payments being FTS/FIS - HELD THAT:- As the payment in question were for FTS/FIS and this is not disputed by the assessee. This is also a finding given by CIT(A) in this para that assessee has not disputed that these services make available the technical knowledge to assessee in India. Now as per the additional evidence filed before us, it is seen that these invoices are in respect of rendering of services to the assessee in respect of certain legal cases filed against the assessee in USA. If that is so then how it can be said that by rendering these services, the concerned parties had made available technical knowledge to assessee in India. As per the invoices of M/s. Angeli Law Group LLC, the invoice is for professional charges for the month of March to October 2012, April 2013 and May 2013 in addition to that, there is commission payment. Thus additional evidence should be admitted and hence, we are admitting the same and restore the entire matter back in both years to the file of ld. CIT(A) for fresh decision. Appeals filed by the assessee are allowed for statistical purposes.
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