https://www.taxtmi.com/caselaws?id=449782 For AY 2006-07, the article notes that non-discrimination clauses in the India-Japan and India-USA treaties were applied to protect purchase payments from disallowance under section 40(a)(i) where the pre-2015 domestic law did not yet treat resident and non-resident purchase payments on the same footing. It also notes that no tax deduction at source arose under section 195(1) for payments to Thailand and Singapore entities that had no permanent establishment in India, because the sums were not chargeable to tax in India. The text further records that a reframed question of law could not enlarge the original reference after judgment. en-us Fri, 16 Feb 2024 00:00:00 +0530 Fri, 03 May 2024 10:44:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=449782 For AY 2006-07, the article notes that non-discrimination clauses in the India-Japan and India-USA treaties were applied to protect purchase payments from disallowance under section 40(a)(i) where the pre-2015 domestic law did not yet treat resident and non-resident purchase payments on the same footing. It also notes that no tax deduction at source arose under section 195(1) for payments to Thailand and Singapore entities that had no permanent establishment in India, because the sums were not chargeable to tax in India. The text further records that a reframed question of law could not enlarge the original reference after judgment. Case-Laws Income Tax Fri, 16 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=449782