Case Law Analysis
|Delhi High Court
Payer residence alone not enough to tax non-resident income under Sec 5(2)(b) | Quashes notices, directs Rs 783 crore TDS refund : Delhi HC
A payer’s residence alone does not trigger tax under Sec 5(2)(b) absent a business connection in India, the Delhi HC ruled, quashing Rs 783 crore of TDS demands on pharma firms. The ruling clarifies source rule, shielding payments from unjust tax claims.