https://www.taxtmi.com/caselaws?id=357598 The Tribunal upheld the Assessing Officer's disallowance of royalty payments made by DKLLC to UOP LLC under Section 40(a)(i) read with Section 195 of the Income Tax Act. It was determined that DKLLC's utilization of patents and IPRs in India for manufacturing products sold in the USA established a significant business connection, rendering the exception under Section 9(1)(vi)(b) inapplicable. Despite DKLLC submitting additional evidence, the Tribunal affirmed the decision, emphasizing the necessity of TDS deduction. DKLLC's appeal was dismissed, and the disallowance of royalty payments was upheld. en-us Thu, 22 Mar 2018 00:00:00 +0530 Mon, 26 Mar 2018 08:37:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=357598 The Tribunal upheld the Assessing Officer's disallowance of royalty payments made by DKLLC to UOP LLC under Section 40(a)(i) read with Section 195 of the Income Tax Act. It was determined that DKLLC's utilization of patents and IPRs in India for manufacturing products sold in the USA established a significant business connection, rendering the exception under Section 9(1)(vi)(b) inapplicable. Despite DKLLC submitting additional evidence, the Tribunal affirmed the decision, emphasizing the necessity of TDS deduction. DKLLC's appeal was dismissed, and the disallowance of royalty payments was upheld. Case-Laws Income Tax Thu, 22 Mar 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=357598