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        Case ID :
        Income Tax

        The Appellate Tribunal addressed the issue of Tax Deducted at...

        TDS u/s 195 - Disallowance u/s 40(a)(i) on 'Royalty' payments to VBSNI overturned by ITAT & Delhi HC. No TDS required.

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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.
                                The Appellate Tribunal addressed the issue of Tax Deducted at Source (TDS) under section 195, specifically disallowance under section 40(a)(i) for payments labeled as 'Royalty' under section 9(1)(vi). The AO disallowed payments to VBSNI equating them to previous payments to MCI Communication Service, treated as 'Royalty'. However, the Tribunal ruled that VBSNI payments did not qualify as 'Royalty' under DTAA, thus no TDS was required. The Tribunal's decision, upheld by the High Court, directed deletion of the disallowance. The appeal by the revenue was dismissed.
                                Note: It is a system-generated summary and is for quick reference only.
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