https://www.taxtmi.com/caselaws?id=793592 Payments to non-resident entities for services rendered outside India were not chargeable to tax in India because the recipients had no permanent establishment or business connection in India and the income neither accrued nor arose in India. As section 195 applies only to sums chargeable under the Act, no tax was deductible at source on such remittances. The resulting disallowance under section 40(a)(i) could not be sustained, and the disallowance was deleted. en-us Wed, 20 May 2026 00:00:00 +0530 Fri, 19 Jun 2026 08:24:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=793592 Payments to non-resident entities for services rendered outside India were not chargeable to tax in India because the recipients had no permanent establishment or business connection in India and the income neither accrued nor arose in India. As section 195 applies only to sums chargeable under the Act, no tax was deductible at source on such remittances. The resulting disallowance under section 40(a)(i) could not be sustained, and the disallowance was deleted. Case-Laws Income Tax Wed, 20 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=793592