https://www.taxtmi.com/caselaws?id=268106 Disallowance under section 40(a)(ia) for professional or technical fees paid to non-residents without tax deduction was required to be re-examined because the applicability of the relevant Double Taxation Avoidance Agreement and sections 9 and 195 had not been examined. The Tribunal noted that the recipients had provided consultancy or technical services, but the effect of treaty provisions on taxability and the resulting disallowance remained unconsidered at the assessment stage. The matter was restored to the Assessing Officer for fresh consideration and recomputation in accordance with law after examining the treaty position. en-us Wed, 05 Aug 2015 00:00:00 +0530 Fri, 20 Nov 2015 10:22:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=268106 Disallowance under section 40(a)(ia) for professional or technical fees paid to non-residents without tax deduction was required to be re-examined because the applicability of the relevant Double Taxation Avoidance Agreement and sections 9 and 195 had not been examined. The Tribunal noted that the recipients had provided consultancy or technical services, but the effect of treaty provisions on taxability and the resulting disallowance remained unconsidered at the assessment stage. The matter was restored to the Assessing Officer for fresh consideration and recomputation in accordance with law after examining the treaty position. Case-Laws Income Tax Wed, 05 Aug 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=268106