https://www.taxtmi.com/caselaws?id=366345 A retrospective amendment plea on TDS liability could not be raised for the first time at final hearing when the assessee had accepted the liability before the lower authorities and had only disputed quantum; the new ground was rejected as belated. In a net-of-tax arrangement for fees for technical services paid to a non-resident under the India-UK DTAA, the payer's assumption of tax liability had to be added to the recipient's income and grossed up for TDS purposes under Section 195A. The treaty fixed the tax rate but did not override the domestic computation mechanism, and absent a specific exemption, the challenge to grossing up failed. en-us Fri, 24 Aug 2018 00:00:00 +0530 Thu, 09 May 2019 16:41:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=366345 A retrospective amendment plea on TDS liability could not be raised for the first time at final hearing when the assessee had accepted the liability before the lower authorities and had only disputed quantum; the new ground was rejected as belated. In a net-of-tax arrangement for fees for technical services paid to a non-resident under the India-UK DTAA, the payer's assumption of tax liability had to be added to the recipient's income and grossed up for TDS purposes under Section 195A. The treaty fixed the tax rate but did not override the domestic computation mechanism, and absent a specific exemption, the challenge to grossing up failed. Case-Laws Income Tax Fri, 24 Aug 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=366345