DCIT, C-4, JAIPUR vs. M/S. JLC ELECTROMET PVT. LTD., JAIPUR
In the result, the appeal of the Department is dismissed
ITA 166/JPR/2020[2016-17]Status: DisposedITAT Jaipur12 Apr 2022AY 2016-17
For Appellant: Shri Mahendra GargieyaFor Respondent: Shri A.S. Nehra, Addl. CIT
Section 142(1)Section 143(2)Section 195Section 40Section 9(1)(vii)
section 40(a)(1) for failing to deduct tax u/s 195 to disallow expenditure to extent of Rs.26.75 crores by Assessment Order-CIT(A) held that amount paid to non resident sub-arranger was in nature of commission / brokerage and not fees for technical services in terms of section 9(1) (vil)-Consequently, CIT(A) held that there