https://www.taxtmi.com/caselaws?id=436814 Payments made under a composite equipment supply and installation arrangement were held not to attract withholding tax where site acceptance testing, installation and training were ancillary and inextricably linked to the sale; under the India-USA DTAA they were not treated as fees for included services or royalty, so section 195 did not apply. The Swiss payment issue was not pressed, while the South African payment issue was remanded only to verify whether tax had in fact been deducted and deposited. Prior period expenses were also allowed because they had crystallised in the relevant year and were considered alongside corresponding prior period income, so the disallowance was deleted. en-us Tue, 06 Sep 2022 00:00:00 +0530 Thu, 20 Apr 2023 10:28:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=436814 Payments made under a composite equipment supply and installation arrangement were held not to attract withholding tax where site acceptance testing, installation and training were ancillary and inextricably linked to the sale; under the India-USA DTAA they were not treated as fees for included services or royalty, so section 195 did not apply. The Swiss payment issue was not pressed, while the South African payment issue was remanded only to verify whether tax had in fact been deducted and deposited. Prior period expenses were also allowed because they had crystallised in the relevant year and were considered alongside corresponding prior period income, so the disallowance was deleted. Case-Laws Income Tax Tue, 06 Sep 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=436814