Payment of related Indian income tax by recipient foreign entity and disallowance for payment made without deduction of TDS

Payment of related Indian income tax by recipient foreign entity and its impact on the impugned disallowance In the present case, we are dealing with a situation in which payment has been made to a non-resident taxpayer but the said non-resident taxpayer has taken into account the receipts in question in his business income and has already filed his income tax return under section 139(1), a copy of which is also produced by the learned Departmental Representative in support of his contention that the recipient non-resident indeed had a tax liability in respect of these amounts. As to what wou...