https://www.taxtmi.com/highlights?id=70405 TDS u/s 195 - Addition u/s 40(a)(ia) - remittance made towards fee for technical services chargeable to tax u/s.9 (1)(vii) or not - in the alleged payments made by the assessee to its sister concern TASE USA, there is no element of income and it is purely reimbursement of expenses - obligation to deduct tax at source u/s 195 does not arise at the moment the payment is made to a non-resident but arises only when such remittances is a sum chargeable to Income Tax u/s 4, 5 and 9 - AT en-us Sat, 17 Jun 2023 10:03:42 +0530 Sat, 17 Jun 2023 10:03:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=70405 TDS u/s 195 - Addition u/s 40(a)(ia) - remittance made towards fee for technical services chargeable to tax u/s.9 (1)(vii) or not - in the alleged payments made by the assessee to its sister concern TASE USA, there is no element of income and it is purely reimbursement of expenses - obligation to deduct tax at source u/s 195 does not arise at the moment the payment is made to a non-resident but arises only when such remittances is a sum chargeable to Income Tax u/s 4, 5 and 9 - AT Highlights Income Tax Sat, 17 Jun 2023 10:03:42 +0530 https://www.taxtmi.com/highlights?id=70405