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TMI Blog2014 (3) TMI 1028X X X X Extracts X X X X X X X X Extracts X X X X ..... imilar commission in earlier years and there was no such disallowance. The issue of T.D.S. never arises as the said person has no permanent establishment in India. The amount was not taxable as the services were not rendered in India. In para 6 of the order passed by the Tribunal, it has referred to the appointment order and also the entire record. The nature of the services rendered have also bee ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the appellant Mr.R.K. Hakani i/by P.S.Sarla for the respondent JUDGEMENT 1 We have heard learned counsel for the appellant. 2 We have perused the orders passed by the Income Tax Appellate Tribunal dated 24th August, 2011 and prior thereto of the Assistant Commissioner, Income Tax (Appeals). 3 The revenue approached the Tribunal against the order of the Commissioner of Income ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... . never arises as the said person has no permanent establishment in India. The amount was not taxable as the services were not rendered in India. In para 6 of the order passed by the Tribunal, it has referred to the appointment order and also the entire record. The nature of the services rendered have also been considered. It is in these circumstances that there was no conclusion that the matter d ..... X X X X Extracts X X X X X X X X Extracts X X X X
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