https://www.taxtmi.com/highlights?id=105150 Tax deduction at source on payments to non-residents arises only if the payment contains income chargeable to tax in India. A tax residency certificate affects access to treaty relief, but its absence does not itself establish a domestic tax charge. Commission for services performed outside India, without evidence of services or business operations in India, is not shown to be taxable in India; consequently, no tax deduction or related disallowance applies, subject to arithmetical verification. Form 15CB descriptions do not conclusively establish a payment's character, which must be determined from agreements, invoices and services rendered. A disallowance may remain where the taxpayer accepts the proposed variation and does not rebut it. en-us Mon, 19 Oct 2026 07:01:13 +0530 Mon, 19 Oct 2026 07:01:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=105150 Tax deduction at source on payments to non-residents arises only if the payment contains income chargeable to tax in India. A tax residency certificate affects access to treaty relief, but its absence does not itself establish a domestic tax charge. Commission for services performed outside India, without evidence of services or business operations in India, is not shown to be taxable in India; consequently, no tax deduction or related disallowance applies, subject to arithmetical verification. Form 15CB descriptions do not conclusively establish a payment's character, which must be determined from agreements, invoices and services rendered. A disallowance may remain where the taxpayer accepts the proposed variation and does not rebut it. Highlights Income Tax Mon, 19 Oct 2026 07:01:13 +0530 https://www.taxtmi.com/highlights?id=105150