Held that the payments had been made to a non-resident not having a permanent establishment and hence the provisions of section 40(a)(i) would not apply. Disallowance was deleted. (AY. 2012-13).
Dy. CIT v. Jagson International Ltd. (2022) 97 ITR 176 (Delhi) (Trib)
S. 40(a)(ia) : Amounts not deductible-Deduction at source-No permanent establishment-Service rendered for a period of 10 days to 27 days-Not liable to deduct tax at source. [S. 9(1)(vii), 40(a)(i)]