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2018 (10) TMI 239 - AT - Income TaxTDS u/s 195 - business connection in India - bearings purchased from foreign companies on which TDS has not been deducted - payments been made to the nonresident which is a foreign company - DTAA provisions - PE in India of the US based company - Held that:- It is clear from the order of the Ld. CIT(A) that he has considered various circulars and case laws and DTAA between USA and India. The assessee is not liable for the deduction of TDS as per section 195 as alleged by the Assessing Officer. Therefore, in view of the above findings of the Ld. CIT(A) the AO was not justified to make addition of ₹ 1,06,53,926/-u/s 40(a)(i) of the Income Tax Act, 1961. - Decided in favour of assessee.
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