https://www.taxtmi.com/caselaws?id=277671 Payments to non-residents that were in substance reimbursements, business reference fees, or training-related amounts were held not chargeable to tax in India under the law then in force, as the recipients had no business presence or permanent establishment in India. On that basis, no withholding obligation arose under Chapter XVII-B, and disallowance under section 40(a)(ia) was unsustainable. A retrospective amendment to the taxability provision could not create a past default for non-deduction when deduction was not required at the time the return was filed. en-us Wed, 10 Feb 2016 00:00:00 +0530 Tue, 18 Dec 2018 05:51:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=277671 Payments to non-residents that were in substance reimbursements, business reference fees, or training-related amounts were held not chargeable to tax in India under the law then in force, as the recipients had no business presence or permanent establishment in India. On that basis, no withholding obligation arose under Chapter XVII-B, and disallowance under section 40(a)(ia) was unsustainable. A retrospective amendment to the taxability provision could not create a past default for non-deduction when deduction was not required at the time the return was filed. Case-Laws Income Tax Wed, 10 Feb 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=277671