TDS not deductible on Payments which become Taxable Due to Retrospective Amendment

ACIT Vs Sociedade de Fomento Industrial Pvt Ltd (Bombay High Court) The case of ACIT Vs Sociedade de Fomento Industrial Pvt Ltd before the Bombay High Court revolves around the retrospective amendment of tax laws and its impact on Tax Deducted at Source (TDS) obligations. The controversy arose from payments made by Sociedade de Fomento Industrial Pvt Ltd (the Assessee) during the previous year 2009-2010, amounting to Rs. 6,94,32,433/- to non-residents for various services. Initially, the Assessee did not deduct TDS, believing the payments were not taxable under Indian tax laws or Double Tax Av...