https://www.taxtmi.com/caselaws?id=443414 Payments under a foreign supply contract were not chargeable to tax in India where the contract was principally for manufacture and supply of a plant outside India, title passed outside India, and the Indian erection and commissioning work was carried out through local contractors. In the absence of evidence that the non-resident supplier itself assembled or commissioned the plant in India, and with no permanent establishment or income accruing or arising in India under the Act or the India-Italy treaty, no withholding obligation arose under section 195. The payer was therefore not treated as an assessee-in-default. en-us Wed, 20 Sep 2023 00:00:00 +0530 Sat, 23 Sep 2023 08:36:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=443414 Payments under a foreign supply contract were not chargeable to tax in India where the contract was principally for manufacture and supply of a plant outside India, title passed outside India, and the Indian erection and commissioning work was carried out through local contractors. In the absence of evidence that the non-resident supplier itself assembled or commissioned the plant in India, and with no permanent establishment or income accruing or arising in India under the Act or the India-Italy treaty, no withholding obligation arose under section 195. The payer was therefore not treated as an assessee-in-default. Case-Laws Income Tax Wed, 20 Sep 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=443414