Court Overturns Disallowance of Fees: No TDS Deduction Expected Due to Retrospective Law Change u/s 195.

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....Disallowance of Professional fees paid to non-residents - Non deduction of TDS u/s 195 - the assessee cannot be expected to deduct TDS on payment made to non-residents on the basis of subsequent amendment to the law with retrospective effect from earlier date, because the assessee cannot foresee the amendment and deduct TDS and hence, we are of the considered view that the AO was erred in disallowing the payment made to non-residents u/s. 40(a)(i) of the Act, for failure to deduct TDS u/s. 195 of the Act. - AT....