https://www.taxtmi.com/caselaws?id=244058 The Tribunal upheld the Commissioner (Appeals)'s decision, stating that the appellant had no obligation to deduct tax at source under Section 195 as the design and development services were not rendered in India. Therefore, no disallowance under Section 40(a)(i) was warranted. The judgment emphasized that tax withholding obligations should be determined based on the law at the time of payment, not retroactive amendments. The appeal was dismissed on 14th February 2014. en-us Fri, 14 Feb 2014 00:00:00 +0530 Mon, 17 Feb 2014 19:44:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=244058 The Tribunal upheld the Commissioner (Appeals)'s decision, stating that the appellant had no obligation to deduct tax at source under Section 195 as the design and development services were not rendered in India. Therefore, no disallowance under Section 40(a)(i) was warranted. The judgment emphasized that tax withholding obligations should be determined based on the law at the time of payment, not retroactive amendments. The appeal was dismissed on 14th February 2014. Case-Laws Income Tax Fri, 14 Feb 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=244058