https://www.taxtmi.com/caselaws?id=800241 Third-party grant disbursement does not displace a resident contracting party's withholding-tax responsibility where it satisfies that party's enforceable liability to a non-resident. Section 195 applies when payment includes income chargeable in India, and Section 40(a)(i) disallows the corresponding expenditure if tax is not deducted. Consideration for technical know-how and allied services used for an Indian industrial project is deemed to accrue in India under Section 9(1)(vii), subject to statutory exceptions. Under the India-UK tax treaty, source follows the person bearing the payment obligation rather than the place of remittance. A UK-funded payment mechanism therefore does not alter Indian taxability or withholding obligations. en-us Sat, 05 Sep 2026 00:00:00 +0530 Sat, 03 Oct 2026 09:32:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800241 Third-party grant disbursement does not displace a resident contracting party's withholding-tax responsibility where it satisfies that party's enforceable liability to a non-resident. Section 195 applies when payment includes income chargeable in India, and Section 40(a)(i) disallows the corresponding expenditure if tax is not deducted. Consideration for technical know-how and allied services used for an Indian industrial project is deemed to accrue in India under Section 9(1)(vii), subject to statutory exceptions. Under the India-UK tax treaty, source follows the person bearing the payment obligation rather than the place of remittance. A UK-funded payment mechanism therefore does not alter Indian taxability or withholding obligations. Case-Laws Income Tax Sat, 05 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800241