https://www.taxtmi.com/caselaws?id=754374 Bareboat charter charges paid to a non-resident Singapore entity were treated as business receipts not chargeable to tax in India because the recipient had no permanent establishment in India and the receipt fell within the treaty-based analysis applied to the contractual arrangement. Tax deduction at source under section 195 arises only when the sum is chargeable to tax in India, so no withholding obligation arose on these facts. As the underlying payment was not taxable in India, disallowance under section 40(a)(i) could not be sustained and was deleted. en-us Wed, 29 May 2024 00:00:00 +0530 Fri, 21 Jun 2024 08:47:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=754374 Bareboat charter charges paid to a non-resident Singapore entity were treated as business receipts not chargeable to tax in India because the recipient had no permanent establishment in India and the receipt fell within the treaty-based analysis applied to the contractual arrangement. Tax deduction at source under section 195 arises only when the sum is chargeable to tax in India, so no withholding obligation arose on these facts. As the underlying payment was not taxable in India, disallowance under section 40(a)(i) could not be sustained and was deleted. Case-Laws Income Tax Wed, 29 May 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=754374