Tax alert: Taxpayer not expected to deduct TDS on notional profit attributed to PE has been saved
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Tax alert: Taxpayer not expected to deduct TDS on notional profit attributed to PE
12 December 2023
The Delhi Bench of the Income-tax Appellate Tribunal, based on facts, has held that the taxpayer cannot be treated as an assessee‑in‑default for not deducting tax at source (TDS), as it cannot be expected to compute TDS on a notional payment, a part of which, is to be attributed towards profit of permanent establishment (PE) of the payee and there was no tax liability on the payee.
