https://www.taxtmi.com/caselaws?id=314359 The Tribunal dismissed the appeal against the disallowance of payment made to an Overseas Entity without withholding tax under Section 195 of the Act. It upheld the CIT(A)'s decision, ruling that the income should be classified as business profit under Article 7 of the India-Philippines DTAA, and, due to the absence of a Permanent Establishment in India, the income is not taxable. The Tribunal's decision was based on precedent related to the DTAA, and no contrary rulings were presented. en-us Sun, 28 Aug 2022 00:00:00 +0530 Mon, 03 Jun 2024 19:29:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=314359 The Tribunal dismissed the appeal against the disallowance of payment made to an Overseas Entity without withholding tax under Section 195 of the Act. It upheld the CIT(A)'s decision, ruling that the income should be classified as business profit under Article 7 of the India-Philippines DTAA, and, due to the absence of a Permanent Establishment in India, the income is not taxable. The Tribunal's decision was based on precedent related to the DTAA, and no contrary rulings were presented. Case-Laws Income Tax Sun, 28 Aug 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=314359