https://www.taxtmi.com/caselaws?id=326839 Tax deduction at source on professional fees paid to non-residents arose only if the sum was chargeable to tax in India; services rendered outside India that did not make available technical knowledge, skill or know-how were not taxable as fees for technical services under the treaty, and a retrospective amendment to section 9 could not retrospectively impose a withholding obligation for an earlier remittance. The article also notes that an AIR entry can trigger inquiry but cannot by itself justify an addition without verification of the underlying material, and foreign tax credit claims must be examined on supporting documents before credit is granted if admissible. en-us Fri, 18 Mar 2016 00:00:00 +0530 Sat, 16 Jul 2016 11:35:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=326839 Tax deduction at source on professional fees paid to non-residents arose only if the sum was chargeable to tax in India; services rendered outside India that did not make available technical knowledge, skill or know-how were not taxable as fees for technical services under the treaty, and a retrospective amendment to section 9 could not retrospectively impose a withholding obligation for an earlier remittance. The article also notes that an AIR entry can trigger inquiry but cannot by itself justify an addition without verification of the underlying material, and foreign tax credit claims must be examined on supporting documents before credit is granted if admissible. Case-Laws Income Tax Fri, 18 Mar 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=326839