The Tribunal held that reinsurance premium paid to non-resident reinsurers was not chargeable to tax in India either under the Income-tax Act or the applicable Double Taxation Avoidance Agreements. Consequently, the assessee was under no obligation to deduct tax at source under section 195 and no disallowance under section 40(a)(i) could be made.  The Tribunal held that the assessee had not made any separate payment of commission to the insurance companies, as the commission had been deducted by the insurers themselves from the reinsurance premium. Since no payment was made by the assessee, the provisions of section 195 were not attracted and the disallowance under section 40(a)(i) was rightly deleted.  The assessee reimbursed survey fees paid to non-resident surveyors for quantification of insurance claims outside India. The Tribunal held that the entire services were rendered outside India, the surveyors had no business connection in India and the reimbursement was not chargeable to tax in India. Accordingly, the assessee was under no obligation to deduct tax at source under section 195.  (AY. 2020-21).