https://www.taxtmi.com/caselaws?id=776851 Disallowance under section 40(a)(i) was unsustainable where commission, inspection and testing charges, and software-use payments were remitted to non-residents for services performed outside India. The recipients had no income accruing or arising in India, the inspection and testing charges were not shown to be fees for technical services, and the software-use payment was not shown to be royalty. As the amounts were not chargeable to tax in India, no obligation to deduct tax at source arose, and the additions were deleted. en-us Mon, 18 Aug 2025 00:00:00 +0530 Wed, 20 Aug 2025 08:34:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=776851 Disallowance under section 40(a)(i) was unsustainable where commission, inspection and testing charges, and software-use payments were remitted to non-residents for services performed outside India. The recipients had no income accruing or arising in India, the inspection and testing charges were not shown to be fees for technical services, and the software-use payment was not shown to be royalty. As the amounts were not chargeable to tax in India, no obligation to deduct tax at source arose, and the additions were deleted. Case-Laws Income Tax Mon, 18 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=776851