https://www.taxtmi.com/highlights?id=63897 Disallowance of claim of communication expenses - Non-deduction of TDS - Royalty as per Article 12 of India-US treaty - the AO/CIT(A) relied upon the Explanations 5 & 6 inserted in sec. 9(1)(vi) of the Act by Finance Act, 2012. Since it is a prospective amendment, the disallowance u/s 40(a)(i) cannot be invoked for the year under consideration relying upon the above said amendment. - AT en-us Mon, 06 Jun 2022 08:28:29 +0530 Mon, 06 Jun 2022 08:28:29 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=63897 Disallowance of claim of communication expenses - Non-deduction of TDS - Royalty as per Article 12 of India-US treaty - the AO/CIT(A) relied upon the Explanations 5 & 6 inserted in sec. 9(1)(vi) of the Act by Finance Act, 2012. Since it is a prospective amendment, the disallowance u/s 40(a)(i) cannot be invoked for the year under consideration relying upon the above said amendment. - AT Highlights Income Tax Mon, 06 Jun 2022 08:28:29 +0530 https://www.taxtmi.com/highlights?id=63897