The assessee failed to deduct tax on professional fees paid to various non-residents. The Assessing...

The assessee failed to deduct tax on professional fees paid to various non-residents. The Assessing Officer (AO) held that the fees were liable to tax in India under the Act and applicable tax treaties. The Commissioner of Income Tax (Appeals) [CIT(A)] deleted substantial disallowance u/s 40(a)(i), holding that the fees were business profits or income from independent personal services not taxable in India due to lack of permanent establishment or fixed base. The Tribunal concurred with CIT(A) that fees paid to UK residents were not taxable in India. Regarding fees to KPMG International Cooperative, Switzerland, following its earlier order, the Tribunal held that contributions were covered by the mutuality concept and not taxable income, up..... .....

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