2014 (2) TMI 1266

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... not be invoked in case in which no services are rendered in India in view of pre amended section 9 (1)(vii) read with Explanation thereto? - This plea, according to the assessee applicant, was accepted by the learned CIT(A) but the Tribunal has not dealt with the same - Held that:- In view of the above discussions as also bearing in mind the fact that the Tribunal indeed did not deal with the abov .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X

..... xability of amounts paid to non-residents, section 40(a)(ia) read with section 195 of the Income Tax Act, 1961, disallowance can not be invoked in case in which no services are rendered in India in view of pre amended section 9 (1)(vii) read with Explanation thereto. This plea, according to the assessee applicant, was accepted by the learned CIT(A) but the Tribunal has not dealt with the same. 2 .....

X X   X X   Extracts   X X   X X

→ Full Text of the Document

X X   X X   Extracts   X X   X X