https://www.taxtmi.com/caselaws?id=792992 Amounts paid under a production sharing contract as claimed reimbursement to a non-resident parent and third parties were treated as taxable for TDS purposes where the assessee did not substantiate the individual expenses with a proper break-up or particulars. The Madras HC held that the arm's length clause did not by itself take the payments outside the tax net, and that tax was deductible under Section 195 of the Income-tax Act, 1961. Consequent liability to interest under Sections 201(1) and 201(1A) was upheld. The alternate claim for relief under the Double Taxation Avoidance Agreement and Section 90 was rejected for the relevant assessment years. en-us Tue, 02 Jun 2026 00:00:00 +0530 Sat, 06 Jun 2026 08:42:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=792992 Amounts paid under a production sharing contract as claimed reimbursement to a non-resident parent and third parties were treated as taxable for TDS purposes where the assessee did not substantiate the individual expenses with a proper break-up or particulars. The Madras HC held that the arm's length clause did not by itself take the payments outside the tax net, and that tax was deductible under Section 195 of the Income-tax Act, 1961. Consequent liability to interest under Sections 201(1) and 201(1A) was upheld. The alternate claim for relief under the Double Taxation Avoidance Agreement and Section 90 was rejected for the relevant assessment years. Case-Laws Income Tax Tue, 02 Jun 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=792992