S. 40(a)(ia) : Amounts not deductible-Deduction at source-Commission to non-resident entities-Services rendered outside India-Not liable to deduct tax at source-Article 7 of the OECD Model Convention. [S.195]

S. 40(a)(ia) : Amounts not deductible-Deduction at source-Interest expenditure-Recipients have shown income in their respective returns-No disallowance could be made-Second proviso to section 40(a)(ia) is declaratory and curative and it has retrospective effect from 1-4-2005. [S. 194A]

S. 40(a)(ia) : Amounts not deductible-Deduction at source-Presumptive taxation scheme-Interest-No disallowance can be made for failure to deduct tax at source. [S. 44AB, 44AD, 194A]

S. 40(a)(ia) : Amounts not deductible-Deduction at source-commission expenses in respect of commission paid to overseas agents-Services are not rendered by foreign agent in India-Not liable to deduct tax at source. [S. 9(1)(vii), 195]

S. 40(a)(ia) : Amounts not deductible-Deduction at source-Leased line charges-Not liable to deduct tax at source-Before insertion of amendment covering leased charges within definition of royalty by Finance Act, 2012 though with retrospective effect from 1-6-1976. [S. 9(1)(vi), 194J]

S. 40(a)(ia) : Amounts not deductible-Deduction at source-Commission-Brokerage-No disallowance on non-deduction of TDS on commission paid by assessee for immovable property.

S. 40(a)(ia) : Amounts not deductible-Deduction at source-Monitoring fees paid to German bank is interest-Not liable to tax under Act-No disallowance warranted for failure to deduct tax at source-DTAA-India-Germany. [Art. 11(3)(b)]

S. 40(a)(ii) : Amounts not deductible-Rates or tax-Education cess is an allowable expenditure.

S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident-payment for purchase of software without deducting TDS-Not affected by subsequent court ruling-No disallowance can be made for failure to deduct tax at source. [S. 9(1)(vi), 194I, 195]

S. 37(1) : Business expenditure-Reimbursement expenses with 15 per cent mark up-Allowable as revenue expenditure.