https://www.taxtmi.com/caselaws?id=330673 A journal entry recorded pursuant to a scheme of arrangement was treated as an accounting adjustment and not an actual payment to the overseas associate enterprise. On that basis, tax deduction at source under section 195 was not attracted, and the foundation for invoking section 40(a)(ia) was absent. The resulting disallowance was deleted in favour of the assessee. en-us Fri, 29 Jul 2016 00:00:00 +0530 Tue, 02 Aug 2016 13:45:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=330673 A journal entry recorded pursuant to a scheme of arrangement was treated as an accounting adjustment and not an actual payment to the overseas associate enterprise. On that basis, tax deduction at source under section 195 was not attracted, and the foundation for invoking section 40(a)(ia) was absent. The resulting disallowance was deleted in favour of the assessee. Case-Laws Income Tax Fri, 29 Jul 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=330673