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Income Tax - Highlights / Catch Notes

Home Highlights November 2020 Year 2020 This

TDS u/s 195 - disallowance u/s 40(a)(i) - payment to a foreign ...


Tax Dispute: Section 40(a)(i) Disallowance for Foreign Testing Payments; Assessee Cites Tax Treaties, Section 9(1)(vii) Exclusion.

November 17, 2020

Case Laws     Income Tax     AT

TDS u/s 195 - disallowance u/s 40(a)(i) - payment to a foreign entity as testing /certification fees outside India - the assessee bonafidely believed that such certification fee was not liable to tax in India, as the same was not covered within the meaning of “ Fee for Technical Services” as provided u/s 9(1) (vii) of the Act and/or the overriding provisions of the Double Taxation Avoidance Agreements stands covered in favour of the assessee - AT

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