“withholding tax”

Standard Chartered Bank (Singapore)Limited, Mumbai vs. The Deputy Commissioner of Income Tax International Taxation Circle 4(2)(2), Mumbai

In the result, appeal of the assessee is allowed

Bench: Shri Narendra Kumar Billaiya, Hon’Ble & Shri Rahul Chaudhary, Hon’Ble

| आयकर अपीलीय अिधकरण "ायपीठ, मुंबई | IN THE INCOME TAX APPELLATE TRIBUNAL “I” BENCH, MUMBAI BEFORE SHRI NARENDRA KUMAR BILLAIYA, HON

Kpmg Assurance and Consulting Services LLP, Mumbai vs. Assistant Commissioner of Income Tax-Circle-16(2), Mumbai

Accordingly, Ground No. 5 & 6 raised by the Revenue are dismissed

Bench: SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

Technical/Included Services (for short ‘FTS’), or (b) as Other Income (in absence of Article on FTS). Thus, the Assessee was under obligation to withhold tax from professional fee paid to such non-residents in terms of Section 195 of the Act. Since the Assessee had failed to deduct ITA No.2272-2276/Mum/2023 ... Assessing Officer denied deduction for the entire amount of INR 11,21,42,029/- holding that the Assessee was under obligation to withhold tax from professional fee paid to non- resident under Section 195 of the Act as the same were chargeable to tax in India in terms of Section

Kpmg Assurance and Consulting Services LLP, Mumbai vs. Assistant Commissioner of Income Tax-Circle-16(2), Mumbai

Accordingly, Ground No. 5 & 6 raised by the Revenue are dismissed

Technical/Included Services (for short ‘FTS’), or (b) as Other Income (in absence of Article on FTS). Thus, the Assessee was under obligation to withhold tax from professional fee paid to such non-residents in terms of Section 195 of the Act. Since the Assessee had failed to deduct tax ... Assessing Officer denied deduction for the entire amount of INR 11,21,42,029/- holding that the Assessee was under obligation to withhold tax from professional fee paid to non- resident under Section 195 of the Act as the same were chargeable to tax in India in terms of Section

Kpmg Assurance and Consulting Services LLP, Mumbai vs. Assistant Commissioner of Income Tax-Circle-16(2), Mumbai

Accordingly, Ground No. 5 & 6 raised by the Revenue are dismissed

Bench: IN THE INCOME TAX APPELLATE TRIBUNAL "I" BENCH, MUMBAI SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

Technical/Included Services (for short ‘FTS’), or (b) as Other Income (in absence of Article on FTS). Thus, the Assessee was under obligation to withhold tax from professional fee paid to such non-residents in terms of Section 195 of the Act. Since the Assessee had failed to deduct ITA No.2272-2276/Mum/2023 ... Assessing Officer denied deduction for the entire amount of INR 11,21,42,029/- holding that the Assessee was under obligation to withhold tax from professional fee paid to non- resident under Section 195 of the Act as the same were chargeable to tax in India in terms of Section

Kpmg Assurance and Consulting Services LLP, Mumbai vs. Assistant Commissioner of Income Tax -16(2), Mumbai

Technical/Included Services (for short ‘FTS’), or (b) as Other Income (in absence of Article on FTS). Thus, the Assessee was under obligation to withhold tax from professional fee paid to such non-residents in terms of Section 195 of the Act. Since the Assessee had failed to deduct tax ... Assessing Officer denied deduction for the entire amount of INR 11,21,42,029/- holding that the Assessee was under obligation to withhold tax from professional fee paid to non resident under Section 195 of the Act as the same were chargeable to tax in India in terms of Section

DCIT, Cir 16(2), Mumbai vs. M/S Kpmg Assurance and Consulting Services LLP, Mumbai

Technical/Included Services (for short ‘FTS’), or (b) as Other Income (in absence of Article on FTS). Thus, the Assessee was under obligation to withhold tax from professional fee paid to such non-residents in terms of Section 195 of the Act. Since the Assessee had failed to deduct tax ... Assessing Officer denied deduction for the entire amount of INR 11,21,42,029/- holding that the Assessee was under obligation to withhold tax from professional fee paid to non resident under Section 195 of the Act as the same were chargeable to tax in India in terms of Section

DCIT, Cir 16(2), Mumbai vs. M/S Kpmg Assurance and Consulting Services LLP, Mumbai

Accordingly, Ground No. 5 & 6 raised by the Revenue are dismissed

Bench: IN THE INCOME TAX APPELLATE TRIBUNAL "I" BENCH, MUMBAI SHRI PRASHANT MAHARISHI, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

Technical/Included Services (for short ‘FTS’), or (b) as Other Income (in absence of Article on FTS). Thus, the Assessee was under obligation to withhold tax from professional fee paid to such non-residents in terms of Section 195 of the Act. Since the Assessee had failed to deduct ITA No.2272-2276/Mum/2023 ... Assessing Officer denied deduction for the entire amount of INR 11,21,42,029/- holding that the Assessee was under obligation to withhold tax from professional fee paid to non- resident under Section 195 of the Act as the same were chargeable to tax in India in terms of Section

DCIT, Cir 16(2), Mumbai vs. M/S Kpmg Assurance and Consulting Services LLP, Mumbai

Technical/Included Services (for short ‘FTS’), or (b) as Other Income (in absence of Article on FTS). Thus, the Assessee was under obligation to withhold tax from professional fee paid to such non-residents in terms of Section 195 of the Act. Since the Assessee had failed to deduct tax ... Assessing Officer denied deduction for the entire amount of INR 11,21,42,029/- holding that the Assessee was under obligation to withhold tax from professional fee paid to non resident under Section 195 of the Act as the same were chargeable to tax in India in terms of Section