https://www.taxtmi.com/caselaws?id=341899 The ITAT Mumbai applied the principle of mutuality to remittances made to KPMG International, holding that complete identity between contributors and participators, use of contributions for the common mandate, and absence of profiteering meant the payments were cost contributions within a mutual set-up rather than income from an external source. As the amounts were not taxable in India in the recipient's hands on that reasoning, the foundation for deduction of tax at source under section 195 did not survive. The assessee was therefore not liable to deduct tax at source. en-us Fri, 07 Apr 2017 00:00:00 +0530 Thu, 01 Jan 2026 13:13:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=341899 The ITAT Mumbai applied the principle of mutuality to remittances made to KPMG International, holding that complete identity between contributors and participators, use of contributions for the common mandate, and absence of profiteering meant the payments were cost contributions within a mutual set-up rather than income from an external source. As the amounts were not taxable in India in the recipient's hands on that reasoning, the foundation for deduction of tax at source under section 195 did not survive. The assessee was therefore not liable to deduct tax at source. Case-Laws Income Tax Fri, 07 Apr 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=341899