https://www.taxtmi.com/caselaws?id=380863 Payments to non-resident individuals resident in Uganda for technical and consultancy services fell under Article 14 of the India-Uganda DTAA, not Article 12, because the treaty specifically treats independent personal services separately from fees for technical services. As the services were taxable only in Uganda on the facts stated, no tax deduction obligation arose under section 195 of the Income-tax Act, 1961. The corresponding disallowance under section 40(a)(i) therefore could not be sustained and was deleted. en-us Fri, 05 Apr 2019 00:00:00 +0530 Wed, 29 May 2019 17:47:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=380863 Payments to non-resident individuals resident in Uganda for technical and consultancy services fell under Article 14 of the India-Uganda DTAA, not Article 12, because the treaty specifically treats independent personal services separately from fees for technical services. As the services were taxable only in Uganda on the facts stated, no tax deduction obligation arose under section 195 of the Income-tax Act, 1961. The corresponding disallowance under section 40(a)(i) therefore could not be sustained and was deleted. Case-Laws Income Tax Fri, 05 Apr 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=380863