DCIT, C-1(1), CHANDIGARH vs. M/S STYLAM INDUSTRIES LTD., CHANDIGARH
In the result, the Department’s appeal in for assessment year
ITA 1033/CHANDI/2017[2013-14]Status: DisposedITAT Chandigarh04 Sept 2024AY 2013-14
Bench: SHRI A.D.JAIN (Vice President), SHRI VIKRAM SINGH YADAV (Accountant Member)
For Appellant: Shri Vineet Krishan, AdvocateFor Respondent: Shri Dharam Vir, JCIT, Sr.DR
Section 14ASection 195Section 40Section 40ASection 5(2)Section 6Section 9(1)
TDS ignoring the detailed finding of the assessing officer that as per section 5 and section 9 of the Act the income is deemed to accrue or arise in India even if the services by the commission agents have been rendered abroad. Further since the right to receive the commission arises in India, the income of such commission agents