IN THE SUPREME COURT OF INDIA CIVIL APPELLATE JURISDICTION

CIVIL APPEAL  NOs.7541-7542  OF 2010 (Arising out of SLP(C) No. 34306-34307 of 2009)

GE India Technology Centre Private Ltd.  …. Appellant(s)

Versus

Commissioner of Income Tax & Anr.  ….Respondent(s)

With

Civil Appeal Nos.7543-7544/2010 @ S.L.P. (C)  Nos.34310-34311/2009, Civil Appeal Nos.7545-7548/2010 @ S.L.P. (C)  Nos.35340-35343/2009, Civil Appeal Nos.7549-7758/2010 @ S.L.P. (C)  Nos.1392-1601/2010, Civil Appeal Nos.7759-7764/2010 @ S.L.P. (C)  Nos.1620-1625/2010, Civil Appeal Nos.7765-7767/2010 @ S.L.P. (C)  Nos.4230-4232/2010, Civil Appeal No.7768/2010 @ S.L.P. (C)  No.4239/2010, Civil Appeal No.7769/2010 @ S.L.P. (C)  No.3329/2010, Civil Appeal No.7770/2010 @ S.L.P. (C)  No.5174/2010, Civil Appeal Nos.7771-7772/2010 @ S.L.P. (C)  Nos.7821-7822/2010, Civil Appeal No.7773/2010 @ S.L.P. (C)  No.8410/2010, Civil Appeal No.7774/2010 @ S.L.P. (C)  No.9701/2010, Civil Appeal Nos.7775-7776/2010 @ S.L.P. (C)  Nos.13440-13441/2010, Civil Appeal No.7777/2010 @ S.L.P. (C)  No.13442/2010 and

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Civil Appeal No.7778/2010 @ S.L.P. (C) No.16264/2010

J U D G M E N T

S.H. KAPADIA, CJI.

1. Leave granted.

2. The short question which arises for determination  

in this batch of cases is – whether the High Court was right  

in  holding  that  the  moment  there  is  remittance  the  

obligation to deduct tax at source (TAS) arises?  Whether  

merely on account of such remittance to the non-resident  

abroad by an Indian company per se, could it be said that  

income chargeable to tax under the Income Tax Act, 1961  

(for short “I.T. Act”) arises in India?

Facts  in  the  leading  case  of  Sonata  Information  Technology Ltd.

3. Appellant(s)  are  the  distributors  of  imported  pre-

packaged  shrink  wrapped  standardized  software  from  

Microsoft  and other  Suppliers  outside  India.   During  the  

relevant assessment year(s) appellant(s) made payments to  

the  said  software  Suppliers  which  according  to  the  

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appellant(s)  represented  the  purchase  price  of  the  

abovementioned software.  The ITO(TDS) held that since the  

sale  of  software  included  a  license  to  use  the  same,  

payments made by the appellant(s) to the foreign Suppliers  

constituted royalty, which was deemed to accrue or arise in  

India.   Therefore,  TAS  was  liable  to  be  deducted  under  

Section 195 of the I.T. Act.  The said finding of the  ITO(TDS)  

was upheld by the Commissioner (A).  In second appeal, the  

ITAT, however, held that the amount paid by appellant(s) to  

the  foreign  software  Suppliers  was  not  “royalty”  and  the  

same did not give rise to any income taxable in India, and  

therefore, the appellant(s) was not liable to deduct TAS.   

4. The  Department  appealed  to  the  Karnataka  High  

Court.  Before the High Court, the Department for the first  

time raised the contention that unless the payer makes an  

application to the ITO(TDS) under Section 195(2) and has  

obtained a permission for non-deduction of the TAS, it was  

not permissible for the payer to contend that the payment  

made  to  the   non-resident  did  not  give  rise  to  “income”  

taxable in India and that, therefore, there was no need to  

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deduct  any  TAS.   This  argument  of  the  Department  was  

accepted by the High Court vide the impugned judgment.  

For reaching this conclusion,  the High Court placed strong  

reliance  on  the  judgment  of  this  Court  in  Transmission  

Corporation  of  A.P.  Ltd.  Vs.  C.I.T. [239  ITR  587(SC)].  

Aggrieved by the said decision, the appellant(s) has come to  

this Court by way of civil appeal(s).   

Analysis of Section 195

5. At  the  outset,  we  quote  hereinbelow  the  relevant  

provisions of Section 195, as it stood at the relevant time.

“195. (1)   Any  person  responsible  for  paying  to  a  non- resident, not being a company, or to a foreign company, any  interest (not being interest on securities) or any other sum  chargeable  under  the  provisions  of  this  Act  (not  being  income chargeable under the head “Salaries”) shall, at the  time of credit of such income to the account of the payee or  at the time of payment thereof in cash or by the issue of a  cheque or draft or by any other mode, whichever is earlier,  deduct income-tax thereon at the rates in force : (2) Where the person responsible for paying any such  sum  chargeable  under  this  Act  (other  than  interest  on  securities and salary) to a non-resident considers that the  whole of such sum would not be income chargeable in the  case of  the recipient,  he may make an application to the  Assessing Officer to determine, by general or special order,  the appropriate proportion of such sum so chargeable, and  upon such determination, tax shall be deducted under sub- section (1) only on that proportion of the sum which is so  chargeable. (3) Subject  to  rules  made under  sub-section (5),  any  

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person  entitled  to  receive  any  interest  or  other  sum  on  which income-tax has to be deducted under sub-section (1)  may  make  an  application  in  the  prescribed  form  to  the  Assessing Officer  for  the grant  of  a  certificate  authorizing  him to receive such interest or other sum without deduction  of  tax  under  that  sub-section,  and  where  any  such  certificate  is  granted,  every  person responsible  for  paying  such interest  or  other  sum to  the  person to  whom such  certificate is granted shall,  so long as the certificate is in  force, make payment of such interest or other sum without  deducting tax thereon under sub-section(1).”  

6. At this stage we may also quote hereinbelow Section  

195 (6) as inserted by Finance Act, 2008 w.e.f. 1.4.2008.

“195(6)  The  person  referred  to  in  sub-section  (1)  shall  furnish the information relating to payment of any sum in  such form and manner as may be prescribed by the Board.”

7. Under Section 195(1), the tax has to be deducted at  

source from interest  (other  than interest on securities)  or  

any other sum (not being salaries) chargeable under the I.T.  

Act in the case of non-residents only and not in the case of  

residents.  Failure to deduct the tax under this Section may  

disentitle the payer to any allowance apart from prosecution  

under Section 276B.  Thus, Section 195 imposes a statutory  

obligation on any person responsible for paying to a non-

resident,  any interest  (not  being interest on securities)  or  

any other sum (not being dividend)  chargeable under the  

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provisions of the I.T. Act,  to deduct income tax at the rates  

in force unless he is liable to pay income tax thereon as an  

agent.   Payment  to  non-residents  by  way  of  royalty  and  

payment  for  technical  services  rendered  in  India  are  

common examples of sums chargeable under the provisions  

of the I.T. Act to which the aforestated requirement of tax  

deduction  at  source  applies.   The  tax  so  collected  and  

deducted  is  required  to  be  paid  to  the  credit  of  Central  

Government in terms of Section 200 of the I.T. Act read with  

Rule 30 of the I.T. Rules 1962.  Failure to deduct tax or  

failure  to  pay  tax  would  also  render  a  person  liable  to  

penalty under Section 201 read with Section 221 of the I.T.  

Act.   In  addition,  he  would  also  be  liable  under  Section  

201(1A) to pay simple interest at 12 per cent per annum on  

the amount of such tax from the date on which such tax  

was deductible to the date on which such tax is actually  

paid.   The  most  important  expression  in  Section  195(1)  

consists of the words “chargeable under the provisions of  

the Act”.  A person paying interest or any other sum to a  

non-resident is not liable to deduct tax if such sum is not  

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chargeable to tax under the I.T. Act.  For instance, where  

there is no obligation on the part of the payer and no right  

to receive the sum by the recipient and that the payment  

does not arise out of any contract or obligation between the  

payer  and  the  recipient  but  is  made  voluntarily,  such  

payments cannot be regarded as income under the I.T. Act.  

It may be noted that Section 195 contemplates not merely  

amounts, the whole of which are pure income payments, it  

also covers composite  payments which has an element of  

income embedded or incorporated in them.  Thus, where an  

amount is payable to a non-resident, the payer is under an  

obligation  to  deduct  TAS  in  respect  of  such  composite  

payments.  The obligation to deduct TAS is, however, limited  

to the appropriate  proportion of income chargeable under  

the Act forming part of the gross sum of money payable to  

the  non-resident.   This  obligation  being  limited  to  the  

appropriate proportion of income flows from the words used  

in Section 195(1), namely,  “chargeable under the provisions  

of the Act”.  It is for this reason that vide Circular No. 728  

dated October 30, 1995 the CBDT has clarified that the tax  

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deductor can take into consideration the effect of  DTAA in  

respect  of  payment  of  royalties  and  technical  fees  while  

deducting TAS.  It may also be noted that Section 195(1) is  

in identical terms with Section 18(3B) of the 1922 Act.  In  

CIT Vs. Cooper Engineering [68 ITR 457] it was pointed  

out that if the payment made by the resident to the non-

resident was an amount which was not chargeable to tax in  

India, then no tax is deductible at source even though the  

assessee had not made an application under Section 18(3B)  

(now  Section  195(2)  of  the  I.T.  Act).   The  application  of  

Section 195(2) pre-supposes that the person responsible for  

making the payment to the non-resident is in no doubt that  

tax is payable in respect of some part of the amount to be  

remitted to a non-resident but is not sure as to what should  

be the portion so taxable or is not sure as to the amount of  

tax to be deducted.  In such a situation, he is required to  

make an application to the ITO(TDS)  for determining the  

amount.  It is only when these conditions are satisfied and  

an application is made to the ITO(TDS) that the question of  

making an order under Section 195(2) will arise.  In fact, at  

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one point of time, there was a provision in the I.T. Act to  

obtain a NOC from the Department that no tax was due.  

That certificate was required to be given to RBI for making  

remittance.  It was held in the case of Czechoslovak Ocean  

Shipping International Joint Stock Company Vs. ITO [81  

ITR 162(Calcutta)]  that an application for NOC cannot be  

said to be an application under Section 195(2) of the Act.  

While deciding the scope of Section 195(2) it is important to  

note that the tax which is required to be deducted at source  

is deductible only out of the chargeable sum.  This is the  

underlying  principle  of  Section  195.   Hence,  apart  from  

Section  9(1),  Sections  4,  5,  9,  90,  91  as  well  as  the  

provisions  of  DTAA  are  also  relevant,  while  applying  tax  

deduction  at  source  provisions.   Reference  to  ITO(TDS)  

under Section 195(2) or 195(3) either by the non-resident or  

by the resident payer is to avoid any future hassles for both  

resident  as  well  as  non-resident.   In  our  view,  Sections  

195(2) and 195(3) are safeguards.  The said provisions are of  

practical  importance.  This reasoning of ours is based on  

the  decision  of  this  Court  in  Transmission  Corporation  

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(supra) in which this Court has observed that the provision  

of Section 195(2) is a safeguard.  From this it follows that  

where a person responsible for  deduction is  fairly  certain  

then he can make his own determination as to whether the  

tax was deductible at source and, if so, what should be the  

amount thereof.   

Submissions and findings thereon  

8. If  the  contention  of  the  Department  that  the  

moment  there  is  remittance the  obligation to deduct  TAS  

arises is to be accepted then we are obliterating the words  

“chargeable  under  the  provisions  of  the  Act”  in  Section  

195(1).  The said expression in Section 195(1) shows that  

the remittance has got to be of a trading receipt, the whole  

or part of which is liable to tax in India.  The payer is bound  

to deduct TAS only if the tax is assessable in India.  If tax is  

not  so  assessable,  there  is  no  question  of  TAS  being  

deducted.  [See  :  Vijay  Ship  Breaking  Corporation  and  

Others Vs. CIT   314 ITR 309]

9. One more aspect needs to be highlighted.  Section  

195 falls in Chapter XVII which deals with collection and  

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recovery.   Chapter XVII-B deals with deduction at source by  

the payer.  On analysis of various provisions of Chapter XVII  

one  finds  use  of  different  expressions,  however,  the  

expression “sum chargeable under the provisions of the Act”  

is used only in Section 195.    For example, Section 194C  

casts an obligation to deduct TAS in respect of “any sum  

paid to any resident”.  Similarly, Sections 194EE and 194F  

inter  alia  provide  for  deduction  of  tax  in  respect  of  “any  

amount” referred to in the specified provisions.  In none of  

the  provisions  we  find  the  expression  “sum  chargeable  

under the provisions of the Act”, which as stated above, is  

an expression used only in Section 195(1).  Therefore, this  

Court  is  required  to  give  meaning  and  effect  to  the  said  

expression.   It  follows,  therefore,  that  the  obligation  to  

deduct  TAS  arises  only  when  there  is  a  sum chargeable  

under the Act.  Section 195(2) is not merely a provision to  

provide  information  to  the  ITO(TDS).   It  is  a  provision  

requiring tax to  be  deducted at  source to  be paid to  the  

Revenue  by  the  payer  who  makes  payment  to  a  non-

resident.   Therefore,  Section  195  has  to  be  read  in  

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conformity with the charging provisions, i.e., Sections 4, 5  

and  9.   This  reasoning  flows  from  the  words  “sum  

chargeable  under  the  provisions  of  the  Act”  in  Section  

195(1).   The fact  that  the  Revenue has not  obtained any  

information per se cannot be a ground to construe Section  

195 widely so as to require deduction of TAS even in a case  

where an amount paid is not chargeable to tax in India at  

all.   We  cannot  read  Section  195,  as  suggested  by  the  

Department, namely, that the moment there is remittance  

the obligation to deduct TAS arises.  If  we were to accept  

such  a  contention  it  would  mean that  on  mere  payment  

income would be said to arise or accrue in India.  Therefore,  

as stated earlier, if  the contention of the Department was  

accepted it would mean obliteration of the expression “sum  

chargeable  under  the  provisions  of  the  Act”  from Section  

195(1).   While  interpreting  a  Section  one  has  to  give  

weightage  to  every  word  used  in  that  section.   While  

interpreting the provisions of the Income Tax Act one cannot  

read  the  charging  Sections  of  that  Act  de  hors  the  

machinery Sections.  The Act is to be read as an integrated  

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Code.   Section 195 appears  in  Chapter  XVII  which deals  

with collection and recovery.  As held in the case of  C.I.T.  

Vs.  Eli  Lilly & Co. (India)  (P.)   Ltd.  [312 ITR 225]  the  

provisions for  deduction of  TAS which is  in Chapter  XVII  

dealing with collection of taxes and the charging provisions  

of  the  I.T.  Act  form one single  integral,  inseparable  Code  

and, therefore, the provisions relating to TDS applies only to  

those sums which are “chargeable to tax” under the I.T. Act.  

It is true that the judgment in Eli Lilly (supra) was confined  

to  Section  192  of  the  I.T.  Act.   However,  there  is  some  

similarity between the two.  If one looks at Section 192 one  

finds that it  imposes statutory obligation on the payer to  

deduct TAS when he pays any income “chargeable under the  

head salaries”.  Similarly, Section 195 imposes a statutory  

obligation on any person responsible for paying to a non-

resident any sum “chargeable under the provisions of the  

Act”, which expression, as stated above, do not find place in  

other Sections of Chapter XVII.  It is in this sense that we  

hold  that  the  I.T.  Act  constitutes  one  single  integral  

inseparable  Code.   Hence,  the  provisions  relating  to  TDS  

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applies  only  to  those  sums  which  are  chargeable  to  tax  

under the I.T. Act.   If the contention of the Department that  

any person making payment to a non-resident is necessarily  

required to deduct TAS then the consequence would be that  

the Department would be entitled to appropriate the moneys  

deposited  by  the  payer  even  if  the  sum  paid  is  not  

chargeable to tax because there is no provision in the I.T.  

Act by which a payer can obtain refund.  Section 237 read  

with Section 199 implies that only the recipient of the sum,  

i.e., the payee could seek a refund.  It must therefore follow,  

if the Department is right, that the law requires tax to be  

deducted  on  all  payments.   The  payer,  therefore,  has  to  

deduct and pay tax, even if the so-called deduction comes  

out of  his own pocket and he has no remedy whatsoever,  

even where the sum paid by him is not a sum chargeable  

under  the  Act.   The  interpretation  of  the  Department,  

therefore, not only requires the words “chargeable under the  

provisions  of  the  Act”  to  be  omitted,  it  also  leads  to  an  

absurd  consequence.    The  interpretation  placed  by  the  

Department would result  in a situation where even when  

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the  income  has  no  territorial  nexus  with  India  or  is  not  

chargeable  in  India,  the  Government  would  nonetheless  

collect tax.    In our view, Section 195(2) provides a remedy  

by  which  a  person  may  seek  a  determination  of  the  

“appropriate proportion of such sum so chargeable” where a  

proportion of the sum so chargeable is liable to tax.  The  

entire  basis  of  the  Department’s  contention  is  based  on  

administrative convenience in support of its interpretation.  

According to the Department huge seepage of revenue can  

take place if persons making payments to non-residents are  

free to deduct TAS or not to deduct TAS.  It is the case of the  

Department that Section 195(2), as interpreted by the High  

Court,  would plug the loophole as the said interpretation  

requires  the  payer  to  make  a  declaration  before  the  

ITO(TDS)  of  payments  made  to  non-residents.   In  other  

words,  according  to  the  Department  Section  195(2)  is  a  

provision  by  which  payer  is  required  to  inform  the  

Department  of  the  remittances  he  makes  to  the  non-

residents by which the Department is able to keep track of  

the remittances being made to non-residents outside India.  

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We  find  no  merit  in  these  contentions.   As  stated  

hereinabove,  Section  195(1)  uses  the  expression  “sum  

chargeable under the provisions of the Act.”  We need to give  

weightage to those words.  Further, Section 195 uses the  

word ‘payer’ and not the word “assessee”.  The payer is not  

an assessee.    The  payer  becomes an assessee-in-default  

only when he fails to fulfill  the statutory obligation under  

Section 195(1).  If the payment does not contain the element  

of income the payer cannot be made liable.  He cannot be  

declared to be an assessee-in-default.  The abovementioned  

contention of the Department is based on an apprehension  

which is ill founded.  The payer is also an assessee under  

the  ordinary  provisions  of  the  I.T.  Act.   When  the  payer  

remits an amount to a non-resident out of India he claims  

deduction or allowances under the Income Tax Act for the  

said  sum  as  an  “expenditure”.   Under  Section  40(a)(i),  

inserted vide Finance Act,  1988 w.e.f.  1.4.89, payment in  

respect of royalty, fees for technical services or other sums  

chargeable  under  the  Income  Tax  Act  would  not  get  the  

benefit of deduction if the assessee fails to deduct TAS in  

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respect  of  payments  outside  India  which  are  chargeable  

under  the  I.T.  Act.   This  provision  ensures  effective  

compliance  of  Section  195  of  the  I.T.  Act  relating  to  tax  

deduction at source in respect of payments outside India in  

respect of royalties, fees or other sums chargeable under the  

I.T. Act.  In a given case where the payer is an assessee he  

will  definitely claim deduction under the I.T. Act for such  

remittance and on inquiry if  the  AO finds that the sums  

remitted outside India comes within the definition of royalty  

or fees for technical service or other sums chargeable under  

the I.T. Act then it would be open to the AO to disallow such  

claim  for  deduction.   Similarly,  vide  Finance  Act,  2008,  

w.e.f. 1.4.2008 sub-Section (6) has been inserted in Section  

195 which requires the payer to furnish information relating  

to payment of any sum in such form and manner as may be  

prescribed  by  the  Board.   This  provision  is  brought  into  

force only from 1.4.2008.  It  will  not apply for the period  

with  which  we  are  concerned  in  these  cases  before  us.  

Therefore, in our view, there are adequate safeguards in the  

Act which would prevent revenue leakage.

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Applicability  of  the  judgment  in  the  case  of  Transmission Corporation (supra)

10. In  Transmission Corporation case (supra) a non-

resident  had  entered  into  a  composite contract  with  the  

resident party making the payments.  The said composite  

contract not only comprised supply of plant, machinery and  

equipment in India, but also comprised the installation and  

commissioning of the same in India.  It was admitted that  

the erection and commissioning of plant and machinery in  

India gave rise to income taxable in India.  It was, therefore,  

clear even to the payer that payments required to be made  

by him to the non-resident included an element of income  

which was exigilble to tax in India.  The only issue raised in  

that  case  was  whether  TDS was  applicable  only  to  pure  

income payments and not to composite payments which had  

an element of income embedded or incorporated in them.  

The  controversy  before  us  in  this  batch  of  cases  is,  

therefore,  quite  different.   In  Transmission  Corporation  

case (supra) it was held that TAS was liable to be deducted  

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by the payer on the gross amount if such payment included  

in it an amount which was exigible to tax in India.  It was  

held that if the payer wanted to deduct TAS not on the gross  

amount but on the lesser amount, on the footing that only a  

portion  of  the  payment  made  represented  “income  

chargeable to tax in India”, then it was necessary for him to  

make an application under Section 195(2) of the Act to the  

ITO(TDS) and obtain his permission for  deducting TAS at  

lesser amount.  Thus, it was held by this Court that if the  

payer had a doubt as to the amount to be deducted as TAS  

he  could  approach  the  ITO(TDS)  to  compute  the  amount  

which was liable  to be deducted at  source.   In our view,  

Section 195(2) is based on the “principle of proportionality”.  

The said sub-Section gets attracted only in cases where the  

payment made is a composite payment in which a certain  

proportion  of  payment  has  an  element  of  “income”  

chargeable  to  tax in India.   It  is  in this  context  that  the  

Supreme  Court  stated,  “If  no  such  application  is  filed,  

income-tax  on  such sum is  to  be  deducted  and  it  is  the  

statutory obligation of the person responsible for paying such  

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‘sum’ to deduct tax thereon before making payment.  He has  

to  discharge  the  obligation  to  TDS”.   If  one  reads  the  

observation of the Supreme Court,  the words “such sum”  

clearly  indicate  that  the  observation  refers  to  a  case  of  

composite payment where the payer has a doubt regarding  

the  inclusion  of  an  amount  in  such  payment  which  is  

exigible to tax in India.  In our view, the above observations  

of  this  Court  in  Transmission  Corporation case  (supra)  

which is put in italics has been completely,  with respect,  

misunderstood by the Karnataka High Court to mean that it  

is not open for the payer to contend that if the amount paid  

by him to the non-resident is not at all “chargeable to tax in  

India”,  then no TAS is required to be deducted from such  

payment.  This interpretation of the High Court completely  

loses sight  of  the plain words of  Section 195(1)  which in  

clear terms lays down that tax at source is deductible only  

from “sums chargeable” under the provisions of the I.T. Act,  

i.e., chargeable under Sections 4, 5 and 9 of the I.T. Act.

11. Before concluding we may clarify that in the present  

case on facts the ITO (TDS) had taken the view that since  

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the sale of the concerned software, included a license to use  

the  same,  the  payment  made  by  appellant(s)  to  foreign  

Suppliers constituted “royalty” which was deemed to accrue  

or  arise  in  India  and,  therefore,  TAS  was  liable  to  be  

deducted under Section 195(1) of the Act.  The said finding  

of  the  ITO(TDS)  was  upheld  by  the  CIT(A).   However,  in  

second appeal,  the ITAT held that such sum paid by the  

appellant(s)  to  the  foreign  software  Supplier  was  not  a  

“royalty” and that the same did not give rise to any “income”  

taxable  in  India  and,  therefore,  the  appellant(s)  was  not  

liable to deduct TAS.  However, the High Court did not go  

into the merits of the case and it went straight to conclude  

that the moment there is remittance an obligation to deduct  

TAS arises, which view stands hereby overruled.   

12. Since the High Court did not go into the merits of  

the case on the question of payment of royalty, we hereby  

set aside the impugned judgments of the High Court and  

remit  these  cases  to  the  High  Court  for  de  novo  

consideration of the cases on merits.  The question which  

the  High  Court  will  answer  is  –whether  on  facts  and  

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circumstances of the case the ITAT was justified in holding  

that the amount(s)  paid by the appellant(s)  to the foreign  

software Suppliers was not “royalty” and that the same did  

not give rise to any “income” taxable in India and, therefore,  

the appellant(s) was not liable to deduct any tax at source?   

13. Subject to what is stated hereinabove, we set aside  

the impugned judgment(s) and remit these cases to the High  

Court  to  answer  the  question  framed  hereinabove.  

Accordingly,  the  appeal(s)  filed  by the  appellant(s)  stands  

allowed with no order as to costs.

…..……………………….CJI        (S. H. Kapadia)

……………………………..J.       (K.S. Radhakrishnan)

New Delhi;  September 09, 2010

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