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2018 (12) TMI 109 - ITAT HYDERABADTDS u/s 195 - payments made to non-residents - non deduction of tds - assessee filed certain documents in support of his contention that the payments made to non-residents were not towards any services performed by them within India and that they do not have any permanent or temporary establishment in India - Held that:- On going through the material, we find that the documents prove that the services were rendered by the agents outside India and therefore, their commission income is not taxable in India. However, since these documents are filed for the first time before us, we deem it necessary to admit these documents and remit the issue to the file of the AO for reconsideration in accordance with law after verification of the documents. Needless to mention that the assessee shall be given a fair opportunity of hearing. - Decided in favour of assessee for statistical purposes.
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