Dismissing the appeal of the Revenue the Court held that there being concurrent findings recorded that the foreign entities receiving the amounts were not Indian residents and subject to tax and that the services rendered were rendered outside India, neither the Tribunal nor the High Court had committed any error in holding against the Department. (AY. 2009-10, 2010-11)
PCIT v. Vedanta Ltd. (2022) 448 ITR 732 / 219 DTR 154 / 329 CTR 265 (2023) 291 Taxman 205 (SC) PCIT v. Matrix Clothing Pvt. Ltd. (2022) 448 ITR 732 / 219 DTR 154 / 329 CTR 265 (SC)
S. 40(a)(ia) : Amounts not deductible-Deduction at source-Non-Residents-Payments were made outside India-Not liable to deduct tax at source.