https://www.taxtmi.com/caselaws?id=346782 Reinsurance premium remitted to a non-resident reinsurer was examined for source-tax deduction and consequent liability under section 201(1A). The analysis followed the connected matter and noted that the foreign reinsurer had no permanent establishment in India, reinsurance was excluded from the treaty deeming rule for insurance enterprises, and the Indian service entity did not amount to a service PE or agency PE. On those facts, the assessee's belief that no tax was deductible was treated as bona fide. As no withholding obligation arose on the remittance, there was no basis to treat the assessee as an assessee in default, and the interest charged under section 201(1A) was not sustainable. en-us Wed, 05 Jul 2017 00:00:00 +0530 Wed, 23 Aug 2017 08:27:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=346782 Reinsurance premium remitted to a non-resident reinsurer was examined for source-tax deduction and consequent liability under section 201(1A). The analysis followed the connected matter and noted that the foreign reinsurer had no permanent establishment in India, reinsurance was excluded from the treaty deeming rule for insurance enterprises, and the Indian service entity did not amount to a service PE or agency PE. On those facts, the assessee's belief that no tax was deductible was treated as bona fide. As no withholding obligation arose on the remittance, there was no basis to treat the assessee as an assessee in default, and the interest charged under section 201(1A) was not sustainable. Case-Laws Income Tax Wed, 05 Jul 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=346782