Section 195 not applies to payment not in the nature of FTS to Non-Resident not having PE in India

Forum Projects Pvt. Ltd. Vs DCIT (ITAT Kolkata) These two appeals preferred by the assessee against the separate orders of the Commissioner of Income Tax(Appeals)-6, Kolkata [hereinafter referred to as ‘Ld. CIT(A)’] dated 12.10.2017 for the assessment year 2011-12 & 2012-13 respectively. 2. The assessee has raised the following grounds: 1. For that on the facts of the case, the order passed by the Ld. CIT(A)-22, Kolkata is completely arbitrary, unjustified and illegal. 2. For that on the facts of the case, the order passed by the Ld. CIT(A) was wrong and dittoing the order of the AO wh...