https://www.taxtmi.com/caselaws?id=301995 Tax was not required to be deducted at source on payments to foreign branches and foreign suppliers where the remittances were not chargeable to tax in India. Section 195 applies only to sums taxable in India, and the services were utilised outside India while the recipients had no permanent establishment in India. Fees for technical services paid by a resident for use in a business carried on outside India fell within the section 9(1)(vii)(b) exception and were not deemed to accrue or arise in India. Treaty protection under section 90 also applied, so disallowance under section 40(a)(i) was not sustainable. en-us Thu, 28 May 2015 00:00:00 +0530 Fri, 29 Apr 2022 20:56:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=301995 Tax was not required to be deducted at source on payments to foreign branches and foreign suppliers where the remittances were not chargeable to tax in India. Section 195 applies only to sums taxable in India, and the services were utilised outside India while the recipients had no permanent establishment in India. Fees for technical services paid by a resident for use in a business carried on outside India fell within the section 9(1)(vii)(b) exception and were not deemed to accrue or arise in India. Treaty protection under section 90 also applied, so disallowance under section 40(a)(i) was not sustainable. Case-Laws Income Tax Thu, 28 May 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=301995