https://www.taxtmi.com/caselaws?id=456014 Bareboat charter hire paid to a Singapore entity was treated as not chargeable to tax in India on the facts found, because the recipient had no permanent establishment in India and the India-Singapore DTAA applied. On that basis, section 195 was not attracted, since tax deduction at source arises only where the payment is chargeable to tax in India. The Tribunal further noted the assessee's claim under the special presumptive regime of section 44BB, supported by maintained and audited books, and held that this regime, read with the treaty position, left no scope for disallowance under section 40(a)(i). The additions were deleted. en-us Thu, 20 Jul 2023 00:00:00 +0530 Fri, 21 Jun 2024 08:14:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=456014 Bareboat charter hire paid to a Singapore entity was treated as not chargeable to tax in India on the facts found, because the recipient had no permanent establishment in India and the India-Singapore DTAA applied. On that basis, section 195 was not attracted, since tax deduction at source arises only where the payment is chargeable to tax in India. The Tribunal further noted the assessee's claim under the special presumptive regime of section 44BB, supported by maintained and audited books, and held that this regime, read with the treaty position, left no scope for disallowance under section 40(a)(i). The additions were deleted. Case-Laws Income Tax Thu, 20 Jul 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=456014