Held that second proviso to section 40(a)(i) inserted with effect from 1-4-2020 is curative in nature and has retrospective effect. The assessee was not liable to deduct tax at source in respect of licence fee paid. (AY. 2014-15)
Celltick Mobile Media (India) (P.) Ltd. v. DCIT (2021) 188 ITD 883 / 87 ITR 32 (SN) (Mum.)(Trib.)
S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident-Royalty-Licence fee-Second proviso to section 40(a)(i) inserted with effect from 1-4-2020 is curative in nature and has retrospective effect-DTAA-India-Israel. [S. 195, 201(1), Art. 5]