https://www.taxtmi.com/caselaws?id=417624 Digital advertising payments to foreign platforms were examined for disallowance under section 40(a)(i) on the theory that they constituted royalty or fees for technical services requiring tax deduction at source. The Tribunal noted that the Supreme Court's ruling in Engineering Analysis materially altered the legal position and that the agreements and surrounding facts had to be reconsidered against that framework. As the controversy required fresh factual and legal examination, the disallowance was not finally sustained or deleted on merits and the matter was remitted for reconsideration. en-us Tue, 14 Dec 2021 00:00:00 +0530 Fri, 28 Jan 2022 09:02:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=417624 Digital advertising payments to foreign platforms were examined for disallowance under section 40(a)(i) on the theory that they constituted royalty or fees for technical services requiring tax deduction at source. The Tribunal noted that the Supreme Court's ruling in Engineering Analysis materially altered the legal position and that the agreements and surrounding facts had to be reconsidered against that framework. As the controversy required fresh factual and legal examination, the disallowance was not finally sustained or deleted on merits and the matter was remitted for reconsideration. Case-Laws Income Tax Tue, 14 Dec 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=417624