Court Rules Company Not Liable for Tax Deduction on Subsidiary Payments u/s 195; Retrospective Law Not Applicable.

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....TDS u/s 195 - Liability to deduct tax on payments made on sub-contract work done - outsourcing a portion of on-site work to its subsidiary in China - Scope of amendment of Finance Act, 2010 in section 9 with retrospective effect - “person” mentioned in section 195 of the Income Tax Act cannot be expected to do the impossible - Order set aside - HC....