Disallowance u/s. 40(a)(i) for non-deduction of TDS from foreign remittance restored back to AO

Sunku Satyanarayana Sanjay Vs DCIT (ITAT Bangalore) ITAT Bangalore held that disallowance u/s. 40(a)(i) for non-deduction of TDS from foreign remittance for business development, project management, marketing and related services is restore back to file of AO with a direction to the assessee to show that the income of Tevlon LLC USA is business income as per Article 5 & 7 of the DTAA. Facts- The assessee is carrying on business activity of export of software development and distinct services as Proprietor of Versatiletech. The return was picked up for scrutiny for the reason of compliance ...