https://www.taxtmi.com/caselaws?id=469765 Interest paid to ABN Amro was held not to qualify for relief from disallowance under section 40(a)(i), because the Tax Residency Certificate relied on by the assessee did not establish a bona fide basis for non-deduction of tax in light of the treaty position and the Revenue's consistent stand. Roaming and interconnect charges paid to other telecom operators were treated as not constituting fees for technical services where the process is automatic and involves no human intervention; accordingly, no tax was deductible under section 194J and the disallowance under section 40(a)(ia) could not stand. The result was a mixed outcome, with the interest disallowance sustained and the roaming-charge disallowance deleted. en-us Mon, 09 Jun 2025 00:00:00 +0530 Thu, 02 Jul 2026 20:38:20 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=469765 Interest paid to ABN Amro was held not to qualify for relief from disallowance under section 40(a)(i), because the Tax Residency Certificate relied on by the assessee did not establish a bona fide basis for non-deduction of tax in light of the treaty position and the Revenue's consistent stand. Roaming and interconnect charges paid to other telecom operators were treated as not constituting fees for technical services where the process is automatic and involves no human intervention; accordingly, no tax was deductible under section 194J and the disallowance under section 40(a)(ia) could not stand. The result was a mixed outcome, with the interest disallowance sustained and the roaming-charge disallowance deleted. Case-Laws Income Tax Mon, 09 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=469765