https://www.taxtmi.com/caselaws?id=462383 Madras HC ruled in favor of the assessee regarding TDS disallowances under Section 40(a)(i) for remittances to foreign entities. The court held that the petitioner correctly applied presumptive taxation rates under Section 44BB rather than business income rates. The Revenue failed to properly assess the non-residents' income or demonstrate that receipts constituted business income. The court emphasized that Section 40(a)(i) disallowances require certainty and exactitude, which was lacking since no formal assessment was conducted. The assessee's conscious analysis of applicable provisions and tax deduction at Section 44BB rates was deemed appropriate given the transaction's parameters. en-us Tue, 27 Aug 2024 00:00:00 +0530 Tue, 17 Jun 2025 18:57:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=462383 Madras HC ruled in favor of the assessee regarding TDS disallowances under Section 40(a)(i) for remittances to foreign entities. The court held that the petitioner correctly applied presumptive taxation rates under Section 44BB rather than business income rates. The Revenue failed to properly assess the non-residents' income or demonstrate that receipts constituted business income. The court emphasized that Section 40(a)(i) disallowances require certainty and exactitude, which was lacking since no formal assessment was conducted. The assessee's conscious analysis of applicable provisions and tax deduction at Section 44BB rates was deemed appropriate given the transaction's parameters. Case-Laws Income Tax Tue, 27 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=462383