2020 (12) TMI 1418

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....'BLE MR. JUSTICE H.T. NARENDRA PRASAD For the Appellant : SRI. K.V. ARAVIND, ADV. For the Respondent : NSHU SHEKHAR SINHA ADV. FOR SRI. R.V. GOUTHAM ADV., SRI. BHUWAR DOOPAR ADV., SRI. YASH VERMANI ADV. JUDGMENT This appeal under Section 260A of the Income Tax Act, 1961 (hereinafter referred to as the Act for short) has been preferred by the revenue. The subject matter of the appeal pe....

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....of said section? (iii) Whether on the facts and circumstances of the case, the tribunal is right in holding that the payments made by assessee to Abbey National Plc, UK are not liable for deduction of TDS under Section 195 of the I.T. Act and as such invoking of Section 40(a)(i) by assessing authority is not proper even when the nature of transactions and materials available on record est....