https://www.taxtmi.com/caselaws?id=77380 SC held that TDS under Section 195 applies only to payments containing income chargeable to tax in India under Sections 4, 5, and 9 of the Income Tax Act. Section 195(2) operates on proportionality principle, applying only to composite payments where a portion constitutes taxable income in India. The court clarified that Karnataka HC misunderstood the Transmission Corporation precedent and overlooked Section 195(1)'s plain language requiring deduction only from sums chargeable under the Act. Matter remitted to HC for determining the nature of payment to non-resident. en-us Thu, 09 Sep 2010 00:00:00 +0530 Wed, 18 Jun 2025 15:15:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=77380 SC held that TDS under Section 195 applies only to payments containing income chargeable to tax in India under Sections 4, 5, and 9 of the Income Tax Act. Section 195(2) operates on proportionality principle, applying only to composite payments where a portion constitutes taxable income in India. The court clarified that Karnataka HC misunderstood the Transmission Corporation precedent and overlooked Section 195(1)'s plain language requiring deduction only from sums chargeable under the Act. Matter remitted to HC for determining the nature of payment to non-resident. Case-Laws Income Tax Thu, 09 Sep 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=77380