https://www.taxtmi.com/caselaws?id=325628 The ITAT ruled in favor of the appellant, emphasizing that disallowance under section 40(a)(i) for failure to withhold tax on payments to an overseas group entity for training programs outside India was unwarranted. The retrospective amendment to section 9(1) by the Finance Act 2010 was deemed unjust as the law cannot impose obligations retrospectively when they were not foreseeable or legally mandated at the time of the transaction. The case underscored the importance of legal clarity and the principle that taxpayers should not be held liable for obligations that were not legally established at the time of the transaction. en-us Tue, 02 Feb 2016 00:00:00 +0530 Fri, 25 Mar 2016 09:34:46 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=325628 The ITAT ruled in favor of the appellant, emphasizing that disallowance under section 40(a)(i) for failure to withhold tax on payments to an overseas group entity for training programs outside India was unwarranted. The retrospective amendment to section 9(1) by the Finance Act 2010 was deemed unjust as the law cannot impose obligations retrospectively when they were not foreseeable or legally mandated at the time of the transaction. The case underscored the importance of legal clarity and the principle that taxpayers should not be held liable for obligations that were not legally established at the time of the transaction. Case-Laws Income Tax Tue, 02 Feb 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=325628