https://www.taxtmi.com/caselaws?id=468560 A retrospective amendment cannot fasten a withholding tax obligation for payments made before the amended provision operated, so disallowance under section 40(a)(i) for IVTC charges, reimbursement of expenses, and training fees paid to non-residents was deleted. The article also notes that the 30% restriction on disallowance under section 40(a)(ia) was treated as substantive and not retrospective, so the assessee did not get that benefit for the relevant years. On dividend distribution tax, the treaty claim under Article 10 of the India-Switzerland DTAA required fresh examination in light of section 115-O, and the matter was remanded for reconsideration. en-us Thu, 28 Nov 2019 00:00:00 +0530 Wed, 13 May 2026 11:36:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=468560 A retrospective amendment cannot fasten a withholding tax obligation for payments made before the amended provision operated, so disallowance under section 40(a)(i) for IVTC charges, reimbursement of expenses, and training fees paid to non-residents was deleted. The article also notes that the 30% restriction on disallowance under section 40(a)(ia) was treated as substantive and not retrospective, so the assessee did not get that benefit for the relevant years. On dividend distribution tax, the treaty claim under Article 10 of the India-Switzerland DTAA required fresh examination in light of section 115-O, and the matter was remanded for reconsideration. Case-Laws Income Tax Thu, 28 Nov 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468560