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        Case ID :
        Income Tax

        TDS u/s 195 - Disallowance of expenses u/s 40 (a) (ia) - as per...

        TDS Non-Deduction u/s 195 Leads to Expense Disallowance; UAE DTAA and Section 44RR Tax Implications Explained.

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                          Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
                            Provisions expressly mentioned in the judgment/order text.
                                TDS u/s 195 - Disallowance of expenses u/s 40 (a) (ia) - as per DTAA with UAE business profits are taxable in the country of origin i.e. UAE as services were provided by the Company registered in UAE and no independent professional has provided services. Even otherwise tax involved was much low as per section 44RR on non-resident engaged in the business of providing services or facilities to be used in exploration of mineral oil only 10% income is taxable and tax thereon would be only 4% applicable on foreign companies. However, after obtaining certificate from Revenue authorities/CA no tax was payable due to DTAA and foreign payments were made only thereafter. - AT
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