https://www.taxtmi.com/caselaws?id=462373 The Madras HC allowed the appeal regarding TDS disallowance under Section 40(a)(i) for payments made to HEPI for crude oil purchase. The court held that the AO erred in not addressing when Section 195(2) application is required, emphasizing that TDS is necessary only if the amount is chargeable to tax in India. The HC noted that both the AO and CIT(A) failed to examine the core issue of whether Section 195 mandates TDS for payments to HEPI when no income is chargeable to tax in India. The matter was remanded to the AO for fresh examination of facts and proper application of law. en-us Mon, 08 Mar 2021 00:00:00 +0530 Mon, 16 Jun 2025 19:09:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=462373 The Madras HC allowed the appeal regarding TDS disallowance under Section 40(a)(i) for payments made to HEPI for crude oil purchase. The court held that the AO erred in not addressing when Section 195(2) application is required, emphasizing that TDS is necessary only if the amount is chargeable to tax in India. The HC noted that both the AO and CIT(A) failed to examine the core issue of whether Section 195 mandates TDS for payments to HEPI when no income is chargeable to tax in India. The matter was remanded to the AO for fresh examination of facts and proper application of law. Case-Laws Income Tax Mon, 08 Mar 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=462373