https://www.taxtmi.com/caselaws?id=216279 Payment to a non-resident satellite service provider was held not chargeable to tax in India on the facts considered, as the receipts did not fall within royalty or fees for technical services and the absence of a permanent establishment brought the income within treaty business income. The Tribunal held that later retrospective amendments to domestic law could not create a withholding obligation for the earlier year, so section 195 was not attracted and disallowance under section 40(a)(i) was deleted. Bad debts actually written off in the books were allowed on the basis of the assessee's write-off and supporting circumstances. Depreciation on leased vehicles was remanded for fresh examination of ownership and evidence. en-us Wed, 29 Aug 2012 00:00:00 +0530 Wed, 13 Aug 2025 15:39:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=216279 Payment to a non-resident satellite service provider was held not chargeable to tax in India on the facts considered, as the receipts did not fall within royalty or fees for technical services and the absence of a permanent establishment brought the income within treaty business income. The Tribunal held that later retrospective amendments to domestic law could not create a withholding obligation for the earlier year, so section 195 was not attracted and disallowance under section 40(a)(i) was deleted. Bad debts actually written off in the books were allowed on the basis of the assessee's write-off and supporting circumstances. Depreciation on leased vehicles was remanded for fresh examination of ownership and evidence. Case-Laws Income Tax Wed, 29 Aug 2012 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=216279