https://www.taxtmi.com/caselaws?id=371831 The ITAT Pune overturned the disallowance of a payment made by a Private Limited Company to Amazon for Web hosting charges under section 40(a)(i) of the Income-tax Act, 1961. The Tribunal held that since the payment was made before the retrospective insertion of Explanation 5 to section 9(1)(vi), no tax deduction at source was required. It was also noted that there was no corresponding amendment in the Double Tax Avoidance Agreement, concluding that Amazon was not liable to tax in India for the charges. The appeal was allowed, and the disallowed amount of &8377;46,28,457/- was deleted. en-us Wed, 05 Dec 2018 00:00:00 +0530 Wed, 12 Dec 2018 13:33:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=371831 The ITAT Pune overturned the disallowance of a payment made by a Private Limited Company to Amazon for Web hosting charges under section 40(a)(i) of the Income-tax Act, 1961. The Tribunal held that since the payment was made before the retrospective insertion of Explanation 5 to section 9(1)(vi), no tax deduction at source was required. It was also noted that there was no corresponding amendment in the Double Tax Avoidance Agreement, concluding that Amazon was not liable to tax in India for the charges. The appeal was allowed, and the disallowed amount of &8377;46,28,457/- was deleted. Case-Laws Income Tax Wed, 05 Dec 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=371831