AO disallowed such amount u/s.40(a)(i)/(ia) of the Act because the assessee failed to deduct tax at source on payments. The assessee filed agreement as additional evidence. The matter was remitted back to the AO for fresh assessment in light of the additional evidence provided by the assessee. (AY. 2010-11)
John Deere India Pvt. Ltd. v. ACIT (2020) 191 DTR 388 / 206 TTJ 213 (Pune)(Trib.)
S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident-Payment towards information systems and Telecommunications-Agreement was filed as additional evidence Matter restored for reconsideration in light of fresh evidence submitted by assessee. [S. 40(a)(ia), 254(1)]