Tax not deductible if no income is held to be taxable in India

DCIT Vs WNS Capital Investment Ltd. (ITAT Mumbai) In the case of Engineering Analysis Centre of Excellence Vs CIT [(2021) 125 taxmann.com 42 (SC)], Hon’ble Supreme Court has, dealing with a materially similar situation i.e. with respect to the obligations of a person under tax withholding requirements, observed that “It is thus clear that the “person” mentioned in section 195 of the Income Tax Act cannot be expected to do the impossible, namely, to apply (the law as it did not exist as the point of time when the obligations in question were being performed) the expanded definition of �...