TDS u/s. 195 not attracted on salary paid outside India towards staff hired outside India

DCIT Vs M V Agro Engineers Pvt. Ltd. (ITAT Delhi) ITAT Delhi held that provisions of section 195 as well as section 40(a)(iii) are not attracted in case of salary paid to staff hired outside India and services were utilised outside India. Accordingly, appeal of the revenue dismissed. Facts- The assessee is a Private Limited Domestic Company engaged in the business of manufacturing of flour mills, rice mills etc. On enquiry, the AO observed that the assessee has made aggregate foreign remittances of INR 21,27,73,715/-. The AO also observed that the assessee could substantiate incurring of commi...