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Vijay Ship Breaking Corpn. & Ors vs Commnr. Of Income Tax, Ahmedabad on 1 October, 2008

8. If the contention of the Department that the moment there is remittance the obligation to deduct TAS arises is to be accepted then we are obliterating the words 'chargeable under the provisions of the Act' in section 195(1). The said expression in section 195(1) shows that the remittance has got to be of a trading receipt, the whole or part of which is liable to tax in India. The payer is bound to deduct TAS only if the tax is assessable in India. If tax is not so assessable, there is no question of TAS being deducted. [See: Vijay Ship Breaking Corpn v. CIT (2009) 314 ITR 309 (SC)]."
Supreme Court of India Cites 11 - Cited by 96 - Full Document

Decta vs Commissioner Of Income-Tax on 17 May, 1996

(ii) The Hon'ble Authority for Advance Rulings, New Delhi in the case of DECTA v. CIT reported in (1999) 237 ITR 190 (AAR) had held that 'the amount of contribution received/receivable to recover part of the cost of technical assistance provided by the applicant under the provisions of its aid programme to the companies assisted by it in India is neither income of the appellant under the provisions of the Income-tax Act nor fees for technical services......"
Authority Tribunal Cites 8 - Cited by 11 - Full Document
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