https://www.taxtmi.com/caselaws?id=243286 The Tribunal allowed the assessee's appeals and deleted the disallowance under Section 40(a)(i) of the Income Tax Act. It held that the training expenses did not constitute "fees for included services" under the Indo-US DTAA and were incurred under Government of India regulations. The Tribunal emphasized the absence of specific technical knowledge transfer and the assessee's bona fide belief in not deducting tax at source, ultimately ruling that the disallowance was not justified. en-us Wed, 14 Aug 2013 00:00:00 +0530 Wed, 29 Jan 2014 10:19:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=243286 The Tribunal allowed the assessee's appeals and deleted the disallowance under Section 40(a)(i) of the Income Tax Act. It held that the training expenses did not constitute "fees for included services" under the Indo-US DTAA and were incurred under Government of India regulations. The Tribunal emphasized the absence of specific technical knowledge transfer and the assessee's bona fide belief in not deducting tax at source, ultimately ruling that the disallowance was not justified. Case-Laws Income Tax Wed, 14 Aug 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=243286