https://www.taxtmi.com/caselaws?id=753538 Payments to overseas associated enterprises for telecom services and business support services were treated as outside the scope of royalty and fees for technical services because the same characterisation had already been decided in the assessee's favour in earlier years. The prior Tribunal view, later affirmed by the jurisdictional High Court, meant no obligation arose to deduct tax at source under section 195 on these payments. As a result, the corresponding disallowance under section 40(a)(i) was not sustainable, and the Revenue's challenge failed. en-us Fri, 31 May 2024 00:00:00 +0530 Tue, 04 Jun 2024 12:38:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=753538 Payments to overseas associated enterprises for telecom services and business support services were treated as outside the scope of royalty and fees for technical services because the same characterisation had already been decided in the assessee's favour in earlier years. The prior Tribunal view, later affirmed by the jurisdictional High Court, meant no obligation arose to deduct tax at source under section 195 on these payments. As a result, the corresponding disallowance under section 40(a)(i) was not sustainable, and the Revenue's challenge failed. Case-Laws Income Tax Fri, 31 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=753538