https://www.taxtmi.com/caselaws?id=771137 Payment to a non-resident service provider for correspondence handling, client database maintenance, communication processing and payment follow-up was not managerial in nature because the work did not involve formulating or implementing managerial policy. As the services were rendered outside India and the consideration was not chargeable to tax in India, no withholding obligation arose under section 195. Consequently, disallowance under section 40(a)(i) could not be sustained. Authorities cited below were distinguished on facts, and the assessee's challenge succeeded. en-us Fri, 16 May 2025 00:00:00 +0530 Wed, 21 May 2025 08:29:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=771137 Payment to a non-resident service provider for correspondence handling, client database maintenance, communication processing and payment follow-up was not managerial in nature because the work did not involve formulating or implementing managerial policy. As the services were rendered outside India and the consideration was not chargeable to tax in India, no withholding obligation arose under section 195. Consequently, disallowance under section 40(a)(i) could not be sustained. Authorities cited below were distinguished on facts, and the assessee's challenge succeeded. Case-Laws Income Tax Fri, 16 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=771137