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Income Tax - Highlights / Catch Notes

Home Highlights March 2016 Year 2016 This

TDS u/s 195 - TDS on the bank guarantee commission paid to a ...

March 19, 2016

Case Laws     Income Tax     AT

TDS u/s 195 - TDS on the bank guarantee commission paid to a foreign bank - no income can be said to have accrued or arisen in India to the VTB bank u/s 4, 5 and 9 of the Act. - AT

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  1. TDS u/ s 195 - Assessee Company was not liable to deduct the tax at source on the bank guarantee commission paid to a foreign bank - AT

  2. TDS u/s 195 - sales commission expenses paid to agents outside India - The commission income earned by foreign agents for services rendered outside India does not accrue...

  3. TDS u/s 195 - disallowance u/s 40(a)(i) - commission paid to non-resident outside India for the services rendered outside India will not fall in the category of the...

  4. TDS u/s 195 - export commission paid to foreign parties - the payment of commission are made to non-resident overseas agents who have no PE or business activities in...

  5. TDS liability on Bank guarantee commission u/s 194A - Assessee in present case paid commission to bank not as an agent - there was no need to deduct TDS on the Bank...

  6. TDS u/s 195 - Disallowance of commission expenditure paid to foreign agents for non-deduction of tax - Assessee has consistently denied that they do not have any...

  7. TDS u/s 195 - expenses in foreign currency - Advertisement and business promotion expenses - do not fall in the nature of technical, managerial or consultancy services -...

  8. TDS u/s 195 - Assessee paid Commission to foreign agent is not the income chargeable to tax in India. Once an income is not chargeable to tax in India then the question...

  9. TDS u/s 195 - As the assessee rendered "International services" outside India which required the payment in question. If this is the position, which has not even been...

  10. TDS u/s 195 - Disallowance of sales commission paid to foreign agents - There is no dispute that these foreign agents do not have permanent establishment in India and...

  11. Commission income belonged to the HUF or assessee - Referring to TDS Certificate issued by Ajnara India Ltd. showing TDS on commission paid to HUF of the assessee and...

  12. Income accrues or arises or deemed to accrue or arise in India - Unexplained foreign income - residential status of the assessee - The Tribunal upheld the CIT(A)'s...

  13. TDS u/s 195 not deducted on payment to Everest Global Inc. for software training services as source of income located outside India and payment made for services outside...

  14. Income deemed to accrue or arise in India - interest income - In these years, the interest income has accrued on the deposits kept by the assessees in HSBC bank, Geneva...

  15. TDS u/s 194H - bank guarantee commission - whether the bank guarantee commission is not in the nature of commission paid to an agent but it is in the nature of bank...

 

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