https://www.taxtmi.com/caselaws?id=416329 An order under section 197(1) rejecting nil deduction of tax was set aside because it lacked reasons and did not explain the basis for directing 10% deduction on the full amount. The Court also noted that the authority failed to consider the amendment to section 10(50) with effect from 01.04.2021, under which income chargeable as royalty or fees for technical services under the Act read with the applicable DTAA is excluded from the equalisation levy framework. As there was no reasoning on the DTAA's applicability to the petitioner's case, the matter was remitted for a fresh, reasoned order after hearing the petitioner. en-us Wed, 22 Dec 2021 00:00:00 +0530 Sat, 25 Dec 2021 08:44:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=416329 An order under section 197(1) rejecting nil deduction of tax was set aside because it lacked reasons and did not explain the basis for directing 10% deduction on the full amount. The Court also noted that the authority failed to consider the amendment to section 10(50) with effect from 01.04.2021, under which income chargeable as royalty or fees for technical services under the Act read with the applicable DTAA is excluded from the equalisation levy framework. As there was no reasoning on the DTAA's applicability to the petitioner's case, the matter was remitted for a fresh, reasoned order after hearing the petitioner. Case-Laws Income Tax Wed, 22 Dec 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=416329