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2019 (7) TMI 613 - HC - Income TaxTDS u/s 195 - non-deduction of tax on commission payable to foreign agents - income as not chargeable to tax in India - disallowance u/s 40(a)(ia) - HELD THAT:- The questions of law as proposed by the revenue has no longer integreta in view of the decision of this Court in the case PR CIT Vs. MGM Exports [2018 (5) TMI 1240 - GUJARAT HIGH COURT] which has been applied saying that a person paying interest or any other sum to a non resident is not liable to deduct tax if such sum is not chargeable to tax under the Act. Tribunal had not erred in law and on facts in upholding the order of the CIT(A) deleting the addition - Decided in favour of assessee.
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