https://www.taxtmi.com/caselaws?id=206847 HC held for the respondent assessee, rejecting Revenue's claim that commission income paid to a non-resident accrued or was deemed to accrue in India and therefore required TDS and disallowance under s.40(a)(ia). The court affirmed that s.195 requires withholding only where the payment is chargeable to tax in India; if the sum is not chargeable in entirety, TDS is not mandatory on the gross payment. The HC upheld the findings of the lower authorities and decided against disallowance of the expenditure. en-us Tue, 08 Nov 2011 00:00:00 +0530 Wed, 20 Aug 2025 10:15:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=206847 HC held for the respondent assessee, rejecting Revenue's claim that commission income paid to a non-resident accrued or was deemed to accrue in India and therefore required TDS and disallowance under s.40(a)(ia). The court affirmed that s.195 requires withholding only where the payment is chargeable to tax in India; if the sum is not chargeable in entirety, TDS is not mandatory on the gross payment. The HC upheld the findings of the lower authorities and decided against disallowance of the expenditure. Case-Laws Income Tax Tue, 08 Nov 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=206847