https://www.taxtmi.com/caselaws?id=756109 The ITAT Delhi ruled in favor of the assessee, holding that without a PE in India, the non-resident company was not liable for TDS under section 195 on offshore supplies. The Tribunal determined that FTS receipts were not taxable in the absence of an FTS article in the India-Thailand DTAA, and without PE establishment, business income attribution was not applicable. Consequently, interest charges under sections 234A, 234B, and 234C were also ruled in favor of the assessee. en-us Tue, 23 Jul 2024 00:00:00 +0530 Fri, 26 Jul 2024 16:57:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=756109 The ITAT Delhi ruled in favor of the assessee, holding that without a PE in India, the non-resident company was not liable for TDS under section 195 on offshore supplies. The Tribunal determined that FTS receipts were not taxable in the absence of an FTS article in the India-Thailand DTAA, and without PE establishment, business income attribution was not applicable. Consequently, interest charges under sections 234A, 234B, and 234C were also ruled in favor of the assessee. Case-Laws Income Tax Tue, 23 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=756109