Pilcom vs Commissioner Of Income Tax

Whether payments made by PILCOM (a joint committee of cricket boards) to non-resident sports associations from its London bank accounts constituted income deemed to accrue or arise in India under Section 115BBA read with Section 9(1) of the Income Tax Act, 1961, thereby attracting TDS obligations under Section 194E --- Held No. Whether the obligation to deduct tax at source under Section 194E is affected by Double Taxation Avoidance Agreements (DTAAs) --- Held No, as TDS is a collection mechanism distinct from final tax liability assessment.