SC Landmark Judgement on TDS on Royalty | Section 195 Vis A Vis DTAA

Engineering Analysis Centre of Excellence Private Limited Vs CIT (Supreme Court of India) 25. The scheme of the Income Tax Act, insofar as the question raised before us is concerned, is that for income to be taxed under the Income Tax Act, residence in India, as defined by section 6, is necessary in most cases. By section 4(1), income tax shall be charged for any assessment year at any rate or rates, as defined by section 2(37A) of the Income Tax Act, in respect of the total income of the previous year of every person. Under section 4(2), in respect of income chargeable under sub-section (1) t...