https://www.taxtmi.com/caselaws?id=429154 Section 14A disallowance is not sustainable where no exempt income has accrued or arisen in the relevant year, and the prospective amendment to the Explanation cannot be applied to earlier assessment years. Payments for onsite project expenses and salary reimbursements are not liable to TDS disallowance under section 40(a)(i) where the arrangement is for manpower deployment or payroll support, no technical knowledge, skill, know-how or process is made available, and the foreign recipient has no permanent establishment in India under the treaty framework. In such circumstances, the amounts are not treated as fees for technical services and no tax deduction obligation arises. en-us Wed, 14 Sep 2022 00:00:00 +0530 Tue, 18 Oct 2022 14:03:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=429154 Section 14A disallowance is not sustainable where no exempt income has accrued or arisen in the relevant year, and the prospective amendment to the Explanation cannot be applied to earlier assessment years. Payments for onsite project expenses and salary reimbursements are not liable to TDS disallowance under section 40(a)(i) where the arrangement is for manpower deployment or payroll support, no technical knowledge, skill, know-how or process is made available, and the foreign recipient has no permanent establishment in India under the treaty framework. In such circumstances, the amounts are not treated as fees for technical services and no tax deduction obligation arises. Case-Laws Income Tax Wed, 14 Sep 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=429154