ACIT, CIRCLE-2(1)(1),AGRA, AGRA vs. EMCO EXPORTS, AGRA
In the result, revenue’s appeal stands dismissed
ITA 415/AGR/2025[2020-21]Status: DisposedITAT Agra15 Jan 2026AY 2020-21
Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singhassessment Year: 2020-21
Section 195Section 250Section 40Section 9
2) is not merely a provision to provide information to the ITO(TDS). It is a provision requiring tax to be deducted at source to be paid to the Revenue by the payer who makes payment to a non-resident. Therefore, Section 195 has to be read inconformity with the charging provisions, i.e., Sections 4, 5 and 9. This reasoning