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Corporate TaxArticle·22 September 2026

Delhi HC says Indian Payer Alone Cannot Create Taxable Accrual for Non-Resident

By J the App

Executive Summary

The Delhi High Court quashed reassessment proceedings against Teva USA concerning payments arising from pharmaceutical marketing rights and a settlement governed by US arrangements. The Court held that the mere fact that Ranbaxy India made the payment from India could not constitute a universal source rule, particularly where the underlying rights, contractual dispute and commercial activity were situated outside India. 

Domain | DT | Corporate Tax

The Position

For a non-resident, ...

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