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2020 (7) TMI 156 - AT - Income TaxDisallowance u/s 40(a)(i) - Selling Expenses payments to non-resident agents - HELD THAT:- It is not in dispute that the issue is same as have already been considered in earlier year by the Tribunal [2017 (9) TMI 820 - ITAT DELHI]. The parties are also same. Tribunal examined the issue in the light of agreement and material on record and found that the agent had their base situated in Abroad and moreover services were also rendered by them outside. Therefore, assessee is not required to deduct tax at source while making payments in question. A.O. in the assessment order has also made disallowance since in earlier year also of the same issue and no TDS have been deducted. Therefore, the facts being identical, no disallowance is required in the matter. We, therefore, following the Order of the Tribunal in the case of assessee for the A.Y. 2010-2011, set aside the Orders of the authorities below and delete the addition. - Decided in favour of assessee.
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