Permali Wallace Pvt. Ltd, Bhopal vs. ITO (It & Tp), Bhopal
ITA 552/IND/2018[2016-17]Status: DisposedITAT Indore09 Nov 2023AY 2016-17
Bench: Shri Vijay Pal Rao & Shri B.M. Biyani
Section 195Section 195rSection 201(1)Section 271CSection 9(1)(i)Section 9(1)(vii)
…ugned payments, if any, in India. Therefore, in such a case, the AO has wrongly invoked section 195A which is not applicable at all.To support his contention, Ld. AR relied upon decision of Hon’ble Kerala High Court in Asian Development Service Vs. CIT (1999) 239 ITR 713 (Ker). 23. However, in view of the fact that we have remanded the original issues to AO for consideration afresh in foregoing paragraphs and the AO’s adjudication will have a bearing on the issue of grossing-up also, we are not answering this question at present. The AO will take a call in accordance with above decision cited by Ld. AR, in case…