Dismissing the appeal of the revenue the Court held that ,payments to professional law firms by way of consultancy fee which did not have any fixed base in India is not taxable in India hence not liable to deduct tax at source.
PCIT v. Cadila Healthcare Ltd. (2019)104 taxmann.com 78/ 262 Taxman 301 (Guj.)(HC) Editorial: SLP of revenue is dismissed, PCIT v. Cadila Healthcare Ltd. (2019) 262 Taxman 301 (SC)
S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident–Payments made to foreign law firms as consultancy fee which did not have any fixed base in India-Not taxable in India-Not liable to deduct tax at source.[S. 9(1)(i), 195]