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TMI Blog2018 (12) TMI 109X X X X Extracts X X X X X X X X Extracts X X X X ..... ORDER PER SMT. P. MADHAVI DEVI, J.M. This is assessee's appeal for the A.Y 2014-15 against the order of the CIT (A)-2, Hyderabad, dated 29th September, 2017. The assessee has raised the following grounds of appeal: " 1. The order of the learned CIT dated 29/9/2017 is contrary to law and facts. 2. The appellant contends that the disallowance of Rs. 78,48,525 u/s 40(a)(ia) of the I.T. act is ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... port agents do not have any permanent establishment in India have not been submitted. The particulars are available and if in doubt, the AO should have made appropriate enquiry. 6. The appellant craves leave to add to, amend or alter any of the aforesaid grounds as the occasion may require". 2. Brief facts of the case are that the assessee company, furnished its return of income for the A.Y 201 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... not be made since TDS was not done on export payments. The assessee explained that the recipient agents do not have permanent establishment in India and therefore, the payments do not attract TDS. The AO was however, not convinced with the assessee's contentions and by holding that since the assessee has made payments to foreign entities, it is required to deduct tax at source, he disallowed the ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... f the agent agreement etc., are filed before us with respect to each of the payment. The learned Counsel for the assessee submitted that these documents goes to prove the contention of the assessee and prayed for admission of the same. 4. The learned DR was also heard. 5. On going through the material, we find that these documents prove that the services were rendered by the agents outside India ..... X X X X Extracts X X X X X X X X Extracts X X X X
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