PR. COMMISSIONER OF INCOME-TAX-14, MUMBAI v. PFIZER PRODUCTS INDIA PVT. LTD.

Retrospective Application of Section 40(a)(ia) Proviso and Non-Liability of TDS on Pure Reimbursements without Profit Markup Regardless of Service Tax Levy.

Court: Bombay High Court
Citation: 2026:BHC-OS:6985-DB
Decision Date: 12-03-2026

List of Laws

Income Tax Act, 1961; Section 40(a)(ia) of the Income Tax Act, 1961; Section 201(1) of the Income Tax Act, 1961; Finance Act, 2012; Service Tax Law (Section 67 of the Finance Act, 1994); Principles of Statutory Interpretation (Retrospective Applicability)