https://www.taxtmi.com/caselaws?id=243837 Tax at source under section 195(1) is deductible only from sums chargeable under the Act, and a final determination that remittances to a Singapore shipping company were not chargeable to tax in India barred disallowance under section 40(a)(i). Earlier revisional and appellate orders had held that the foreign company had no permanent establishment in India, the income was taxable in Singapore, and sections 44B, 195 and 40(a)(i) did not apply; those orders had attained finality. The retrospective amendment to section 195 did not change that position, and the alternate-remedy objection was rejected because the assessment order was patently unsustainable. en-us Wed, 05 Feb 2014 00:00:00 +0530 Wed, 13 May 2015 16:09:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=243837 Tax at source under section 195(1) is deductible only from sums chargeable under the Act, and a final determination that remittances to a Singapore shipping company were not chargeable to tax in India barred disallowance under section 40(a)(i). Earlier revisional and appellate orders had held that the foreign company had no permanent establishment in India, the income was taxable in Singapore, and sections 44B, 195 and 40(a)(i) did not apply; those orders had attained finality. The retrospective amendment to section 195 did not change that position, and the alternate-remedy objection was rejected because the assessment order was patently unsustainable. Case-Laws Income Tax Wed, 05 Feb 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=243837