Interest u/s 201(1A) Applies Only When Income is Taxable in India; Otherwise, It's Tax Neutral.

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....TDS u/s 195 - interest u/s. 201(IA) - The levy of interest to compensate for the delay in realization of taxes, in the event of the taxability of subject income being upheld, is reasonably protected. In a situation in which, however, no income is held to be taxable in India, no demands under section 201 r.w.s. 195- including demand under section 201(1A) r.w.s. 195., which are inherently in the nature of vicarious liability, survive. Viewed thus, the present dispute is wholly tax neutral. - AT....