Withholding tax scope: disallowance under section 40(a)(i) based on the portion chargeable to tax as determined under section 195. The taxable portion of a remittance, as determined by the Assessing Officer for the purposes of tax deduction at source, shall form the basis for any disallowance under section 40(a)(i); determinations made under the statutory pre determination mechanisms will similarly govern such disallowance.