ITAT directs AO to Consider ‘Tax Residency Certificate’ (TRC ) before deciding withholding tax issue

IN THE ITAT MUMBAI BENCH ‘L’ Raymond Ltd. v/s. Deputy Director of Income-tax (IT) IT APPEAL NO. 4050 (MUM.) OF 2009 [ASSESSMENT YEAR 2005-06] JUNE 20, 2012 ORDER Amit Shukla, Judicial Member This appeal has been filed by the assessee against the order dated 29-4-2009, passed by the CIT(A)-XXXI, Mumbai, in relation to proceedings and order passed under Section 195 for the assessment year 2005-2006. The assessee is aggrieved by the finding of the CIT(A) that the payments made towards fees for registration of trade-mark applications in UAE to Emirates Advocates, is pa...