TDS u/s 195 cannot be deducted in case no title in goods passed from foreign suppliers to assessee outside India

Organising Committee for Winter Games, 2009 Vs DCIT (ITAT Delhi)

Conclusion: Since the title in goods passed from foreign suppliers to assessee outside India at the port of shipment and AO failed to show as to how income of foreign parties was chargeable to tax in India, therefore,  no income had accrued to foreign parties in India in terms of section 5 and section 9, therefore, section 195 did not apply to payments.

Held: Assessee – society was reg

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