https://www.taxtmi.com/highlights?id=68175 TDS u/s 195 - Disallowance u/s 40(a)(ia) - non-deduction of TDS on payment of management fees - It is not even the allegation of the revenue that the non-residents had made available to the assessee, the knowledge generated in the course of rendering managerial services. In our view the services rendered were purely managerial services and by no stretch of imagination can be considered as making available any technical knowledge, experience, skill, know-how or processes, to the assessee. - No TDS liability - AT en-us Wed, 08 Feb 2023 11:17:56 +0530 Wed, 08 Feb 2023 11:17:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=68175 TDS u/s 195 - Disallowance u/s 40(a)(ia) - non-deduction of TDS on payment of management fees - It is not even the allegation of the revenue that the non-residents had made available to the assessee, the knowledge generated in the course of rendering managerial services. In our view the services rendered were purely managerial services and by no stretch of imagination can be considered as making available any technical knowledge, experience, skill, know-how or processes, to the assessee. - No TDS liability - AT Highlights Income Tax Wed, 08 Feb 2023 11:17:56 +0530 https://www.taxtmi.com/highlights?id=68175