https://www.taxtmi.com/caselaws?id=341899 Whether payments to a Switzerland-based association attracted TDS under s.195 depended on whether the receipts were income chargeable to tax in India. The Tribunal held the principle of mutuality applied because there was complete identity between contributors and participators, the contributions were applied only to further the association's mandate, and there was no profit element as the fund could only be expended for, or returned to, the contributors themselves; consequently, the payments did not constitute taxable income, rendering s.195 inapplicable (treaty aspect not determinative). Revenue's appeal was dismissed and the order of the CIT(A) was upheld. 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 Whether payments to a Switzerland-based association attracted TDS under s.195 depended on whether the receipts were income chargeable to tax in India. The Tribunal held the principle of mutuality applied because there was complete identity between contributors and participators, the contributions were applied only to further the association's mandate, and there was no profit element as the fund could only be expended for, or returned to, the contributors themselves; consequently, the payments did not constitute taxable income, rendering s.195 inapplicable (treaty aspect not determinative). Revenue's appeal was dismissed and the order of the CIT(A) was upheld. Case-Laws Income Tax Fri, 07 Apr 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=341899