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2015 (12) TMI 968 - DELHI HIGH COURT

2015 (12) TMI 968 - DELHI HIGH COURT - TMI - Disallowance under Section 40 (a) (i) - ITAT deleted the addition - whether the services rendered by the agents to the Assessee were in the nature of fee for technical services - Held that:- ITAT has analysed the agreements in question entered into by the Assessee with the foreign entities (agents) and concluded that the services rendered by the Ďagentsí were purely in the nature of advancement of the business of the Assessee which could not be catego .....

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Grup ISM (2015 (6) TMI 10 - DELHI HIGH COURT). Consequently, this Court finds no substantial question arises for determination on this issue.- Decided in favour of assessee.

Whether the payments could have been made by the Assessee to the foreign entities towards tour expenses without deduction of TDS? - Held that:- The CIT (A) has held against the Revenue on this issue. Where the recipient of the payment is not liable to tax in India, the question of deducting tax at source on paymen .....

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ment Years ( AYs ) 2007-08 and 2008-09, the first question projected by the Revenue is whether the ITAT has erred in deleting disallowance of ₹ 2,77,62,022 made by the Assessing Officer ( AO ) under Section 40 (a) (i) of the IT Act in AY 2007-08 on the ground that the services rendered by the agents to the Assessee were in the nature of fee for technical services. 2. On the said issue, the ITAT has analysed the agreements in question entered into by the Assessee with the foreign entities ( .....

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