Amount paid to seconded personnel not liable for deduction of tax at source

HIGH COURT OF BOMBAY Commissioner of Income-tax Versus Petroleum India International IT APPEAL NO. 3653 OF 2009 JANUARY 10, 2013 ORDER 1. In this appeal, though the Revenue has raised four questions of law in the appeal memorandum, only the following two questions are pressed for consideration : “(a) Whether the Tribunal was justified in setting aside the disallowance of Rs. 3,93,72,038/- made by the AO under Section 40(a)(iii) of the Act when the assessee failed to deduct tax at source on such amount? (b) Whether on true and proper interpretation of Section 91(1) the as...