Settlement amounts not taxable for withholding tax purposes, so no tax deduction at source was required.

Settlement amounts payable under the agreement were found not chargeable to tax for section 195 purposes, so no withholding tax deduction was required. The Authority applied the same reasoning as in the connected advance ruling applications and answered the questions in the negative.

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Issues: Whether the settlement amount payable under the settlement agreement was chargeable to tax so as to attract deduction of tax at source under section 195.

Analysis: The questions raised were stated to be covered by the common ruling already pronounced in the connected advance ruling applications. The Authority applied the same ruling to the present case.

Conclusion: The questions were answered in the negative. The settlement amount was held not to be chargeable to tax for the purpose of section 195, and no deduction of tax at source was required.

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