https://www.taxtmi.com/caselaws?id=463999 Payments remitted to the foreign entity were not treated as chargeable to tax in the manner alleged by the revenue, so no deduction obligation arose under Section 195. On that basis, the payer could not be held to be an assessee in default under Section 201(1), and corresponding interest liability under Section 201(1A) also failed. The Court further held that disallowance under Section 40(a)(i) was not justified and that the remittances were not fees for technical services under Section 9(1)(vii) or Article 13(4)(c) of the India-UK DTAA. All substantial questions were answered in favour of the assessee. en-us Tue, 01 Dec 2020 00:00:00 +0530 Fri, 26 Sep 2025 16:36:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=463999 Payments remitted to the foreign entity were not treated as chargeable to tax in the manner alleged by the revenue, so no deduction obligation arose under Section 195. On that basis, the payer could not be held to be an assessee in default under Section 201(1), and corresponding interest liability under Section 201(1A) also failed. The Court further held that disallowance under Section 40(a)(i) was not justified and that the remittances were not fees for technical services under Section 9(1)(vii) or Article 13(4)(c) of the India-UK DTAA. All substantial questions were answered in favour of the assessee. Case-Laws Income Tax Tue, 01 Dec 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=463999