https://www.taxtmi.com/caselaws?id=341272 Tax deduction at source on royalty or fees for technical services paid to a non-resident arises only when the sum is chargeable to tax in India at the relevant stage. Under the India-Italy DTAA, the income was taxable in India only on payment, so no withholding obligation arose on mere credit to the recipient's account. Once actual payment was made, tax became deductible, and the more beneficial domestic rate under section 115A, read with section 90(2), applied. Interest under section 201(1A) could therefore be levied only for any delay in remitting tax after payment, not from the earlier credit date. en-us Tue, 28 Mar 2017 00:00:00 +0530 Wed, 05 Apr 2017 07:07:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=341272 Tax deduction at source on royalty or fees for technical services paid to a non-resident arises only when the sum is chargeable to tax in India at the relevant stage. Under the India-Italy DTAA, the income was taxable in India only on payment, so no withholding obligation arose on mere credit to the recipient's account. Once actual payment was made, tax became deductible, and the more beneficial domestic rate under section 115A, read with section 90(2), applied. Interest under section 201(1A) could therefore be levied only for any delay in remitting tax after payment, not from the earlier credit date. Case-Laws Income Tax Tue, 28 Mar 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=341272