Deductibility of cross-border payments limited where withholding tax not applied; later withholding permits retrospective deduction. Amendment to section 40 replaces clause (a)(i) to disallow deduction for interest, royalty, fees for technical services or other sums payable outside ... Summary
Deductibility of cross-border payments limited where withholding tax not applied; later withholding permits retrospective deduction.
Amendment to section 40 replaces clause (a)(i) to disallow deduction for interest, royalty, fees for technical services or other sums payable outside India where tax has not been paid or deducted under Chapter XVII-B, while allowing deduction in the previous year if such tax is subsequently paid or deducted; royalty and fees for technical services are defined by reference to the explanations to clause (vi) and (vii) of sub-section (1) of section 9, and clause (d) is omitted.
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