https://www.taxtmi.com/caselaws?id=374596 The Tribunal dismissed the Revenue's appeal, directing the AO to delete the disallowance under Section 40(a)(i) of the Income Tax Act. It held that the payments to UK and Singapore subsidiaries did not constitute 'Fees for Technical Services' and were not taxable in India, as they did not provide technical knowledge or skills. The Tribunal emphasized that TDS was not required if the payment was not chargeable to tax in India, in line with the DTAA provisions. en-us Wed, 05 Dec 2018 00:00:00 +0530 Tue, 05 Feb 2019 06:14:40 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=374596 The Tribunal dismissed the Revenue's appeal, directing the AO to delete the disallowance under Section 40(a)(i) of the Income Tax Act. It held that the payments to UK and Singapore subsidiaries did not constitute 'Fees for Technical Services' and were not taxable in India, as they did not provide technical knowledge or skills. The Tribunal emphasized that TDS was not required if the payment was not chargeable to tax in India, in line with the DTAA provisions. Case-Laws Income Tax Wed, 05 Dec 2018 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=374596