TDS on fees paid for marketing service rendered outside India

Onprocess Technology India Pvt. Ltd. Vs DCIT (ITAT Kolkata) These cross appeals filed by the assessee and revenue respectively are against the order of Ld. CIT(A)-1, Kolkata dated 28.03.2016 for AY 2012-13. 2. First of all we take up assessee’s appeal in ITA No. 1047/Kol/2016. The ground nos. 1 to 6 of the assessee are against the action the of the Ld. CIT(A) to confirm the disallowance of marketing expenses of Rs.2,96,05,045/- paid to foreign companies u/s. 40(a)(i) of the Income-tax Act, 1961 (hereinafter referred to as the “Act”). 3. Briefly stated facts of the case are that a company...