https://www.taxtmi.com/caselaws?id=257286 Production expenses incurred for film production, whose genuineness was not questioned and for which no specific unverifiable items were identified, warranted only a limited ad hoc disallowance of cash expenses. Payments to a Thailand-based entity for overseas shooting were not taxable in India where it had no Indian permanent establishment and the services were rendered abroad; consequently, no tax deduction obligation or disallowance for non-deduction arose. Similarly, modelling fees for services performed in Nepal were not taxable in India under the applicable treaty's specific services provisions, and the residual article could not apply. Penalty required consequential recomputation after quantum relief. en-us Fri, 28 Mar 2014 00:00:00 +0530 Mon, 09 Mar 2015 09:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=257286 Production expenses incurred for film production, whose genuineness was not questioned and for which no specific unverifiable items were identified, warranted only a limited ad hoc disallowance of cash expenses. Payments to a Thailand-based entity for overseas shooting were not taxable in India where it had no Indian permanent establishment and the services were rendered abroad; consequently, no tax deduction obligation or disallowance for non-deduction arose. Similarly, modelling fees for services performed in Nepal were not taxable in India under the applicable treaty's specific services provisions, and the residual article could not apply. Penalty required consequential recomputation after quantum relief. Case-Laws Income Tax Fri, 28 Mar 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=257286