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 sc

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