https://www.taxtmi.com/caselaws?id=374129 Payments to foreign consortium members were analysed under section 195 on the basis that the foreign suppliers were separately responsible for equipment supply and warranty, with no income found to accrue or arise in India on those remittances. Payments to public sector bodies and other executing agencies for construction and sports infrastructure were treated as falling within section 194C, with withholding required; however, relief from being treated as an assessee in default under section 201 depended on recipient compliance evidence and verification before the Assessing Officer. A payment routed through the State Trading Corporation also raised section 194C issues, but the invoice structure and material-service split required factual examination before determining the withholding position. en-us Mon, 10 Dec 2018 00:00:00 +0530 Fri, 09 Sep 2022 15:19:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=374129 Payments to foreign consortium members were analysed under section 195 on the basis that the foreign suppliers were separately responsible for equipment supply and warranty, with no income found to accrue or arise in India on those remittances. Payments to public sector bodies and other executing agencies for construction and sports infrastructure were treated as falling within section 194C, with withholding required; however, relief from being treated as an assessee in default under section 201 depended on recipient compliance evidence and verification before the Assessing Officer. A payment routed through the State Trading Corporation also raised section 194C issues, but the invoice structure and material-service split required factual examination before determining the withholding position. Case-Laws Income Tax Mon, 10 Dec 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=374129