ACIT, CIRCLE-2(1)(1),AGRA, AGRA vs. EMCO EXPORTS, AGRA

In the result, revenue’s appeal stands dismissed

Bench: : Shri S. Rifaur Rahman & Shri Sunil Kumar Singhassessment Year: 2020-21

288 ITR 408 wherein it was held that for section 195 is to be attracted, the services rendered by the nonresident should have been rendered in India and also should have been used in India and that, this twin tests has to be satisfied for section 195 is to be attracted. We find that the Legislation introduced the Explanation