Dismissing the appeal of the revenue the Court held that ; there was no factual determination that the non-resident agent who operated outside India had any income which arose in India. Without these foundational facts, the question of applying section 195 of the Act would not arise. (AY.2001-02)
CIT v. Maruti Suzuki India Ltd. (2018) 407 ITR 165 (Delhi) (HC)
S. 40(a)(i) : Amounts not deductible – Deduction at source -Non-resident-Operated outside India- Not liable to deduct tax at source. [S.195]