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2019 (8) TMI 1126 - AT - Income TaxTDS u/s 195 - addition on account of export commission paid to foreign parties u/s 40(a)(ia) - PE in India - HELD THAT:- CIT(A) rightly observed that the payment of commission are made to non-resident overseas agents who have no PE or business activities in India and the services are also rendered outside India as such no income is arising to the non-resident commission agent in India and as such no TDS is deductible u/s 194-H which is applicable for resident Indians only. Thus, there is no need to interfere with the findings of the CIT(A). The appeal of the Revenue is dismissed.
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