TDS on income accrued outside the Indian territory for services rendered

PCIT Vs EIH Ltd. (Calcutta High Court) Whether on the facts and in the circumstances of the case, the Learned Tribunal erred in law in deleting the disallowance of Rs.1,30,77,646/- under Section 40(a)(i) on account of professional and consultancy charges to non residents by ignoring the fact that such fees are subject to tax in India under Section 9(1) read with Section 195 of the act? The Division Bench in its judgement dated 23rd July, 2018 found that the Tribunal held the addition to be erroneous and has considered in detail the nature and expenses in respect of which the assessee was sough...