Divya Creations v. ACIT (2020) 83 ITR 433 (Delhi)(Trib.)

S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident –Service rendered outside India-Not liable to deduct tax at source.

Allowing the appeal Tribunal held that in the light of the agreement and material on record on the findings that the agents had their bases abroad, the services were rendered by them outside India and the assessee was not required to deduct tax at source while making the payments in question, for this year also, the disallowance was to be deleted. (AY. 2014-15)