power to appoint sub-agents / representatives.
However, it is the responsibility of the agents to pay the sub-
agents. The assessee can ask the agent ... appoint sub-agents
does not mean that they (agents) have the authority to
conclude contracts. The terms of appointment of sub-agents
given at page
power to appoint sub-agents/representatives. However, it is the responsibility of the agents to pay the sub-agents. The assessee can ask the agent ... length. Therefore, the agents were all independent agents.
(g) There is no evidence to show that the agents had as a matter of fact
connectivity between the assessee and the premises of the
agent. The agents were "dependent agents" within the meaning of article ... agents were economically dependent on the assessee company,
agents being dependent upon technology and software. According to the AO, the
agents were not independent agent
whether the agents were 'independent
agents' under article 5.4 , three conditions were required to be satisfied
in order that an agent might ... merely because the agents are not
'independent agents', it does not automatically follow that they are
'dependent agents' under the DTAA
made by the Assessing Officer for
disallowing commission paid to sub-agent.
4.1 The facts in respect of issue in dispute are that ... mention of a specific services to be provided by the sub-
agent and the percentage of commission of payment on the
basis of the services
airlines. The assessee is getting business directly as well as through
sub agents. The return for the A.Y. 2003-04 was filed ... after netting off direct expenses on account of commission
paid to sub agents, rebate and discount allowed and TC charges (i.e.
terminal charges) paid
successive periods of one year each. The agents could appoint sub-
agents for carrying out the activity. They have to maintain records
and measure ... appoint sub-agents does not mean that they
(agents) have the authority to conclude contracts. The terms of
appointment of sub-agents given at page
customer
business segment") and to the AE ("Related-party/ Sub-agent business segment")] based
purely on own conjectures and surmises. The consequential ... only that of
agent and no more. In sub-agent segment, assessee merely acts on behalf of the AE
and all the risk is that
commission/discount/handling charges paid to sub agents. Hence, for
this willful default, penalty provisions of section 271C of the Act are
attracted ... 2010
respective account of sub agents, then it was obligatory on the part of
the assessee to deduct TDS and deposit the same
brief facts are: The assessee employed
following sub-agents for utilizing their services in her business activity of
earning commission from sale of boilers ... have been filed. Similarly, the actual nature
of services rendered by sub agents have not been explained by the assessee.
As actual rendering of services
