supported by
any invoices/cash memos issued to various customer/retailers. Assessee
is agent of BSNL and carrying out various activities which include sale ... disallowance, holding that there was no principal to agent relationship
between assessee and the customers. Now, undoubtedly, the
'commission' in question
commissions
are never paid to the end customer but are paid to the agents
and facilitators. What is paid to the customer is in accounting ... maintaining liaison with overseas customers. In the past too
commissions have been paid by the Appellant to the foreign
agents and the same have been
commissions
are never paid to the end customer but are paid to the agents
and facilitators. What is paid to the customer is in accounting ... maintaining liaison with overseas customers. In the past too
commissions have been paid by the Appellant to the foreign
agents and the same have been
held that merely because the agent is not independent would not
automatically create an agency PE. The agent should be able to exercise the authority ... their businesses has reference to activity of the
agent tested by reference to normal customs in the case in issue. It has reference to normal
stamping duty as well as commission
paid to the direct selling agents for procuring the loan assignments and
it is not dependent upon the working ... entered into between the assessee and the customers. Since the
commission is paid to the direct selling agents, for their services in
sourcing hire
facility at Hassan in South India. Furthermore, that
the customer of the assessee constitutes dependent agent PE of AAP in India as
per the provisions
engaged in undertaking advertising services for its
customers/AEs in the capacity of an agent. As part of its
business operation, the assessee facilitated placement ... assessee to vendor was recovered from the
respective customers or AEs. In the event customer failed to pay
any such amount to the advertisement agency
agents to
the assessee only outside India. These agents were not
having business connection in India nor any permanent
establishment in India. These agents were ... agents in India, insofar as
services were rendered by the agents outside India. Thus,
the commission paid to these agents was not chargeable
that the dealer merely acted as an agent and a link
between the company and the ultimate customer and the relationship between
the company
banker, which is given to its customer
and is only a copy of the customer‟s account in the books maintained ... bank. The bank does not act as an agent of the customer nor can it be said
that the banker maintains the pass book under
