https://www.taxtmi.com/caselaws?id=449967 Grossing up under Section 195A requires tax borne by the payer to be treated as part of the non-resident's income for TDS computation, and the DTAA rate under Section 90 remains relevant to that exercise. The text also notes that the inclusive definition of income under Section 2(24) and the exemption in Section 10(6A) affect the grossing-up analysis. It records that the Madras High Court answered the substantial question against the assessee and declined to admit an additional ground based on a later retrospective amendment, while the Special Leave Petitions were dismissed as withdrawn with the question of law kept open. en-us Mon, 19 Feb 2024 00:00:00 +0530 Mon, 11 May 2026 10:54:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=449967 Grossing up under Section 195A requires tax borne by the payer to be treated as part of the non-resident's income for TDS computation, and the DTAA rate under Section 90 remains relevant to that exercise. The text also notes that the inclusive definition of income under Section 2(24) and the exemption in Section 10(6A) affect the grossing-up analysis. It records that the Madras High Court answered the substantial question against the assessee and declined to admit an additional ground based on a later retrospective amendment, while the Special Leave Petitions were dismissed as withdrawn with the question of law kept open. Case-Laws Income Tax Mon, 19 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=449967