Tax Management India. Com
Law and Practice  :  Digital eBook
Research is most exciting & rewarding
  TMI - Tax Management India. Com
Follow us:
  Facebook   Twitter   Linkedin   Telegram
Income Tax - Highlights / Catch Notes

Home Highlights February 2023 Year 2023 This

TDS u/s 195 - Disallowance u/s 40(a)(ia) - non-deduction of TDS ...

Case Laws     Income Tax

February 8, 2023

TDS u/s 195 - Disallowance u/s 40(a)(ia) - non-deduction of TDS on payment of management fees - It is not even the allegation of the revenue that the non-residents had made available to the assessee, the knowledge generated in the course of rendering managerial services. In our view the services rendered were purely managerial services and by no stretch of imagination can be considered as making available any technical knowledge, experience, skill, know-how or processes, to the assessee. - No TDS liability - AT

View Source

 


 

You may also like:

  1. TDS disallowance u/s 40(a)(i) for non-deduction on overseas payments towards patent fees, reimbursement of official fees and professional fees, treating such payments as...

  2. The ITAT addressed various issues: disallowance u/s 40(a)(ia) for year-end provisions, deduction u/s 10AA for interest income, TDS u/s 195 for subscription fees, foreign...

  3. Disallowance of Professional fees paid to non-residents - Non deduction of TDS u/s 195 - the assessee cannot be expected to deduct TDS on payment made to non-residents...

  4. TDS u/s 195 - disallowance u/s. 40(a)(i) for non deduction of TDS on payment to non-resident which is in nature of FTS(Fee for Technical Service) - beneficial provisions...

  5. Disallowance of expenses u/s.40(a)(ia) - Non deduction of TDS u/s 195 - at the time of payment made by the assessee to non-residents, there was an ambiguity in the...

  6. Addition u/s 40(a)(ia) - Non-deduction of TDS - year end provisions was made by assessee in respect of expenses - As regards to the claim of the assessee that in...

  7. Non deduction of TDS - Disallowance u/s 40(a)(ia) - payment made on account of offshore supply of equipments - the subject mentioned payments are not chargeable to tax...

  8. TDS u/s 194J or 194C - disallowance u/s. 40(a)(ia) - Short deduction of TDS - Carriage Fees/Channel Placement fees - the provisions of section u/s.40(a)(ia) of the Act...

  9. TDS u/s 195 - Disallowance of management fee paid by invoking the provisions of section 40(a)(i) - whether payment of management fees cannot be regarded as fees for...

  10. TDS u/s 195 - non deduction of TDS on expenses paid/remitted abroad - Fee for Technical Services (FTS) - We endorse the findings of the Ld. CIT(A) that the payments made...

  11. Disallowance u/s. 40(a)(ia) - TDS u/s 195 - no PE - Article 12 of DTAA between India and USA - Royalties and Fees for Included Services - payments for subscription fees...

  12. TDS u/s 194H or 192 - addition u/s 40(a)(ia) - Non-deduction of TDS on payment of commission to directors - appellant considered payment as salary and deducted TDS u/s...

  13. TDS (withholding tax) u/s 195 - Disallowance u/s 40(a)(i) - non-deduction of tax at source on payment made towards membership/subscription fee - principle of mutuality-...

  14. The assessee company made payments for IT service charges to a foreign entity without deducting tax at source (TDS) u/s 195. The Assessing Officer treated these expenses...

  15. TDS u/s 195 - Addition u/s 40(a)(ia) - no liability for deduction of tax at source arose under Section 195 in the case of mobilization and demobilization costs...

 

Quick Updates:Latest Updates