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Non Discrimination – Scope of provision : Where period in issue was assessment year 2006-07, amendment brought about in section 40(a) by virtue of Financial Act, 2014 would have no relevance, therefore, equal treatment or non-discrimination clause obtaining in articles 24(3) and 26(3) of India-Japan/India-USA DTAAs would apply with regard to payment for purchases made by assessee from its group companies and, thus, Tribunal had rightly deleted disallowance made by Assessing Officer on account of non-deduction of tax at source (TAS) under section 40(a)(i) – Commissioner of Income-tax-II v. Mitsubishi Corporation India (P.) Ltd. – [2024] 159 539 (Delhi)



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