https://www.taxtmi.com/caselaws?id=205675 A payer who makes payments to a non-resident must first characterise whether any part of the payment has income character; if the payer, acting in bona fide belief, concludes no part is chargeable to tax and does not apply for a lower or nil withholding order, the payer is not statutorily obliged to deduct tax at source on that part. Payments that represent an integrated sale price where installation, testing and training are ancillary to the equipment sale are treated as part of the purchase consideration and not as taxable fees for technical services; consequence: no TDS required on the ancillary portion and decision favours the assessee. en-us Fri, 09 Apr 2010 00:00:00 +0530 Thu, 05 Feb 2026 16:39:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=205675 A payer who makes payments to a non-resident must first characterise whether any part of the payment has income character; if the payer, acting in bona fide belief, concludes no part is chargeable to tax and does not apply for a lower or nil withholding order, the payer is not statutorily obliged to deduct tax at source on that part. Payments that represent an integrated sale price where installation, testing and training are ancillary to the equipment sale are treated as part of the purchase consideration and not as taxable fees for technical services; consequence: no TDS required on the ancillary portion and decision favours the assessee. Case-Laws Income Tax Fri, 09 Apr 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=205675