[ compiled answer ]
law as at 14 Aug 2026 · settled
What happens to withholding when the Indian payer bears the tax under a net-of-tax contract?
The compiled answer
s.393(10), Income-tax Act 2025 (old s.195A): the income is grossed up — increased to the amount which, after deduction, equals the net amount payable. At the s.207(2) 20% rate a net-100 royalty becomes 125 gross; at the India–US 15% treaty rate it becomes 117.65 (100/0.85), gate permitting.
Pinpoint
s.393(10), Income-tax Act 2025
String-verified quote
“the income shall be increased to an amount which after deduction of tax as per provisions of this Chapter becomes equal to the net amount payable”
source: provision:IN.ITA2025.S393-2 — verified at load; a quote that stops matching its source is a compile error
Computed by a deterministic engine over compiled law — no generative model in the evaluation path. JSON twin: /t/s195_gross_up_net_contracts.json · Ask with YOUR facts: GET /compute?lookup=… · MCP: POST https://lrlabs.ai/mcp (lookup_compiled_rule)