TDS u/s 195 - Commission paid - when undisputedly TEI is not ...

Case Laws Income Tax

August 27, 2020

TDS u/s 195 - Commission paid - when undisputedly TEI is not having any Permanent Establishment (PE) in India the income of TEI received as commission from assessee company was not chargeable to tax in India as the same was neither accrued in India nor received in India and as such was not required to deduct tax at source u/s 195 of the Act. - AT

View Source

← Previous Next →

TDS u/s 195 - Commission paid - when undisputedly TEI is not ...

Case Laws Income Tax

August 27, 2020

You may also like:

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...

TDS u/s 195 - Disallowance u/s 40(a)(i) - the said income in the hands of non-resident has to be considered in the light of the provisions of DTAA between India and the...

TDS u/s 195 - existence of permanent establishment (PE) - payment made to various non-resident being during the year under consideration for purchase, installation and...

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...

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...

Income taxable in India - PE in India - Once we hold that in the light of the present legal position, existence of dependent agency permanent establishment in wholly tax...

TDS u/s 195 - payment of commission for export of goods - payment of commission to its associated enterprises in Foreign Countries that did not have any permanent...

TDS u/s 195 - Disallowance of commission u/s 40(a)(ia) - the commission has been paid to various nonresident entities in respect of sales affected by the assessee...

Disallowance of commission paid - excessive expense on commission - the average rate of commission paid by the assessee to others in respect of rice was 20, but rate of...

Withholding Tax (TDS) u/s 195 - payment of distribution fees - treatment as Royalty / FTS - DAPE [Dependent Agent Permanent Establishment - the Assessee cannot be...

TDS u/s 195 - compensation received for loss of business - the foreign company does not have permanent establishment in India - thus payments are not liable for taxation...

TDS u/s 195 - assessee in default - payroll services rendered by IBM Philippines to the assessee - as per Article 7(1) of Indian Philippines DTAA, the business profits...

TDS u/s 195 - Disallowance of commission income - there was no requirement for the assessee to deduct tax at source on such payments made to non-resident agents based...

The Appellate Tribunal addressed the issue of TDS u/s 195 on sub contract charges paid to a Singapore company. The Non-Resident company argued it falls under Section...

TDS u/s 195 - disallowance made u/s 40(a)(i) - export commission paid to overseas agents, who arrange for exports and procure export orders for the assessee - the said...

Quick Updates: