https://www.taxtmi.com/caselaws?id=413302 Management, administrative, legal, human resources, IT, reporting and risk functions under a UK management arrangement were treated as managerial services, not fees for technical services under the applicable treaty. Because the payment was not chargeable to tax on that basis, the TDS obligation under section 195 did not arise and the disallowance under section 40(a)(i) was deleted. The claim for disallowance under section 37(1) for management fee and IT charges was restored to the Assessing Officer for verification in light of the accepted position in earlier years and the unilateral advance pricing arrangement. The claim for short TDS credit was also remanded for factual verification from TDS certificates and records. en-us Thu, 30 Sep 2021 00:00:00 +0530 Fri, 08 Oct 2021 08:21:26 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=413302 Management, administrative, legal, human resources, IT, reporting and risk functions under a UK management arrangement were treated as managerial services, not fees for technical services under the applicable treaty. Because the payment was not chargeable to tax on that basis, the TDS obligation under section 195 did not arise and the disallowance under section 40(a)(i) was deleted. The claim for disallowance under section 37(1) for management fee and IT charges was restored to the Assessing Officer for verification in light of the accepted position in earlier years and the unilateral advance pricing arrangement. The claim for short TDS credit was also remanded for factual verification from TDS certificates and records. Case-Laws Income Tax Thu, 30 Sep 2021 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=413302