https://www.taxtmi.com/caselaws?id=468560 Retrospective amendments cannot impose a withholding-tax obligation on payments made when the relevant income was not taxable under the then-existing law; accordingly, disallowances for IVTC charges, expense reimbursements and training charges paid to non-residents under section 40(a)(i) were deleted. The amendment limiting disallowance for non-deduction of tax to 30% was treated as substantive rather than retrospective, so the claimed restriction was unavailable for the relevant years. The dividend distribution tax claim under the India-Switzerland treaty required reconsideration because all treaty-contentions had not been addressed, and was remanded for fresh adjudication. 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 Retrospective amendments cannot impose a withholding-tax obligation on payments made when the relevant income was not taxable under the then-existing law; accordingly, disallowances for IVTC charges, expense reimbursements and training charges paid to non-residents under section 40(a)(i) were deleted. The amendment limiting disallowance for non-deduction of tax to 30% was treated as substantive rather than retrospective, so the claimed restriction was unavailable for the relevant years. The dividend distribution tax claim under the India-Switzerland treaty required reconsideration because all treaty-contentions had not been addressed, and was remanded for fresh adjudication. Case-Laws Income Tax Thu, 28 Nov 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=468560