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2018 (3) TMI 580 - AT - Income TaxLiability to deduct TDS u/s 195 - whether TDS provisions as applicable not only to the expenses incurred by the PE in India but also by the Head Office or any other branch of the assessee in any country, if such expenses are debited to the P&L accounts of the PE in India - Held that:- The appellant was not liable to deduct tax at source out of the expenses incurred by the head office, as no payments were made by the P.E., nor was any liability incurred by it. The action of the assessing officer in holding the assessee to be an assessee in default u/s 201 is misplaced. - Decided against revenue.
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