In the result, the appeal for assessment year 2011-2012
Bench: Shri Chandra Poojari, Am & Shri George George K, Jm
190 of the Act wherein it is clarified that the tax is deductible at source under Chapter XVII-B, only in respect of payments of "income" or "any sum" comprising an element of Income. 4.5 The DCIT and DRP have failed to consider the fact that tax had already been deducted by USTIPL at the time of payment of such