https://www.taxtmi.com/caselaws?id=763331 Where payments to foreign affiliates were found to be at arm's length and the recipient entities had no permanent establishment in India, no taxable income in India was shown and no obligation to deduct tax at source arose under Section 195. On that footing, the premise for disallowance under Section 40(a)(i) and for treating the payer as an assessee in default under Section 201(1) failed. The Delhi HC accordingly held that reassessment proceedings founded on the contrary assumption could not survive, and the notices and consequential assessment order were quashed. en-us Tue, 06 Aug 2024 00:00:00 +0530 Tue, 17 Dec 2024 11:44:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=763331 Where payments to foreign affiliates were found to be at arm's length and the recipient entities had no permanent establishment in India, no taxable income in India was shown and no obligation to deduct tax at source arose under Section 195. On that footing, the premise for disallowance under Section 40(a)(i) and for treating the payer as an assessee in default under Section 201(1) failed. The Delhi HC accordingly held that reassessment proceedings founded on the contrary assumption could not survive, and the notices and consequential assessment order were quashed. Case-Laws Income Tax Tue, 06 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=763331