CIT v. United India Insurance Co ( 2019) 111 taxmann.com 217 (Mad) (HC) Editorial: SLP is granted to the revenue , CIT v. United India Insurance Co ( 2020) 117 taxmann.com 849/ 273 Taxman 187 SC)

S. 9(1)(i): Income deemed to accrue or arise in India – Business connection – Survey fees paid outside India –Service rendered outside India – Not liable to deduct tax at source [ S.195 ]

Dismissing the appeal of the revenue survey  fees paid for non -resident outside the country  , the assessee is not liable to deduct tax at source since entire services of the surveyors were rendered outside India . (AY. 2011-12)