https://www.taxtmi.com/caselaws?id=306904 Marketing and business-support services rendered offshore by a Singapore subsidiary were treated as non-taxable in India where they were promotional in nature, the non-resident had no permanent establishment in India, and the India-Singapore DTAA make-available condition was not satisfied. On that basis, the payer's withholding obligation under section 195 did not arise and disallowance under section 40(a)(i) was not attracted. Circular No. 23 of 1969 remained available for the relevant year because its later withdrawal could not operate retrospectively to deny relief for an earlier period. en-us Thu, 01 Mar 2018 00:00:00 +0530 Sun, 05 Mar 2023 16:59:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=306904 Marketing and business-support services rendered offshore by a Singapore subsidiary were treated as non-taxable in India where they were promotional in nature, the non-resident had no permanent establishment in India, and the India-Singapore DTAA make-available condition was not satisfied. On that basis, the payer's withholding obligation under section 195 did not arise and disallowance under section 40(a)(i) was not attracted. Circular No. 23 of 1969 remained available for the relevant year because its later withdrawal could not operate retrospectively to deny relief for an earlier period. Case-Laws Income Tax Thu, 01 Mar 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=306904