https://www.taxtmi.com/caselaws?id=122142 Fees for technical services paid to an Austrian enterprise were treated as not taxable in India because the India-Austria treaty applied only to the extent the services were actually performed in India, and the services here were rendered wholly from Austria. As no income was chargeable to tax in India, no tax deduction obligation arose under section 195, the need for a certificate under section 195(2) did not survive, and disallowance under section 40(a)(i) could not be sustained. The resulting disallowance was deleted in favour of the assessee. en-us Fri, 09 Jul 2010 00:00:00 +0530 Wed, 08 Aug 2012 18:15:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=122142 Fees for technical services paid to an Austrian enterprise were treated as not taxable in India because the India-Austria treaty applied only to the extent the services were actually performed in India, and the services here were rendered wholly from Austria. As no income was chargeable to tax in India, no tax deduction obligation arose under section 195, the need for a certificate under section 195(2) did not survive, and disallowance under section 40(a)(i) could not be sustained. The resulting disallowance was deleted in favour of the assessee. Case-Laws Income Tax Fri, 09 Jul 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=122142