https://www.taxtmi.com/caselaws?id=428601 Management fee paid under a master support services arrangement to an overseas associated enterprise was not chargeable to tax in India because the corresponding receipts had been held not to constitute fees for included services under article 12(4) of the India-USA DTAA. As the sum was not taxable in India, no obligation to withhold tax arose under section 195 of the Income-tax Act, 1961. The consequential disallowance under section 40(a)(i) therefore lacked foundation and was deleted. en-us Tue, 20 Sep 2022 00:00:00 +0530 Tue, 04 Oct 2022 18:45:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=428601 Management fee paid under a master support services arrangement to an overseas associated enterprise was not chargeable to tax in India because the corresponding receipts had been held not to constitute fees for included services under article 12(4) of the India-USA DTAA. As the sum was not taxable in India, no obligation to withhold tax arose under section 195 of the Income-tax Act, 1961. The consequential disallowance under section 40(a)(i) therefore lacked foundation and was deleted. Case-Laws Income Tax Tue, 20 Sep 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=428601