#section 40(a)(ia)
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710 articlesIncome Tax

Income Tax
Disallowance cannot be made by only giving weight age to nomenclature and without seeing real purpose for payment
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Section 40(a)(ia) proposed to apply to Income from Other Sources
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Need to Rationalize Provisions of Section 40(a)(ia) of Income Tax, 1961
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Sections 194C(6) & Section 194C(7) are independent of each other
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Second proviso to s. 40(a)(ia) inserted by F.A. 2013 – Whether retrospective?
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Tax on services rendered abroad by foreign firms to Indian CA Firm
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Sec. 40 (a)(i) is discriminatory & not applicable to Indo-US DTAA
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Disallowance U/s. 40(a)(ia) not justified for Freight charges paid but not claimed as expense
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No TDS on payment to non-resident which not taxable in India
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Technical services Meaning – articulated by SC
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Technical services denote services for special needs of Customer: SC
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S. 40(a)(iii): No specified period for TDS deposit in claiming salary expenses
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100% expense disallowance for Cash Payment should go
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Income Tax
