https://www.taxtmi.com/caselaws?id=358755 TDS liability on reimbursements, marketing support charges and legal representation fees depended on whether the payments were chargeable to tax in India and within the withholding net under sections 195 and 201. The Tribunal found the factual record incomplete: the assessee had not proved that the subsidiary reimbursement was pure cost-to-cost payment, the record did not establish whether the marketing services were rendered or utilised in India, and the treaty and source-of-service facts for the New Zealand legal fees were not conclusively examined. Each issue was therefore remitted to the Assessing Officer for fresh verification; the TDS grounds were allowed for statistical purposes. en-us Thu, 12 Apr 2018 00:00:00 +0530 Wed, 18 Apr 2018 06:26:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=358755 TDS liability on reimbursements, marketing support charges and legal representation fees depended on whether the payments were chargeable to tax in India and within the withholding net under sections 195 and 201. The Tribunal found the factual record incomplete: the assessee had not proved that the subsidiary reimbursement was pure cost-to-cost payment, the record did not establish whether the marketing services were rendered or utilised in India, and the treaty and source-of-service facts for the New Zealand legal fees were not conclusively examined. Each issue was therefore remitted to the Assessing Officer for fresh verification; the TDS grounds were allowed for statistical purposes. Case-Laws Income Tax Thu, 12 Apr 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=358755