TDS on Commission paid to NRs for services rendered outside India not become deductible for mere withdrawal of circular

Asstt. CIT Vs. Nuova Shoes (ITAT Agra) The assessing officer completed assessments under section 143(3) for the assessment years 2011-12 and 2012-13 wherein the learned assessing officer has not made any disallowance in respect of the payment of commission to the foreign agents residing in the country, with which India has entered into DTAA. Apropos assessing officer’s contention that the CBDT, vide Circular No. 7, dt. 22-10-2009, had withdrawn its Circulars Nos. 23, dt. 23-7-1969, 163, dt. 29-5-1975 and 786, dt. 7-2-2000, which were based on Circular No. 23; that the Circular N...