https://www.taxtmi.com/caselaws?id=450749 The ITAT Ahmedabad remanded a TDS case where the assessee made annual payments to overseas educational institutions (IBO, Cambridge) for authorization, enrollment, license, and registration fees. The assessee argued these payments weren't royalty for trademark use and no TDS was required under section 195. The ITAT held that without analyzing the basis of invoices raised by overseas institutions and the discount offered, it cannot be concluded whether payments qualify as royalty. The matter was restored to the AO to determine the actual nature and basis of the lump sum fees charged by overseas entities. en-us Fri, 08 Mar 2024 00:00:00 +0530 Mon, 11 Mar 2024 10:48:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=450749 The ITAT Ahmedabad remanded a TDS case where the assessee made annual payments to overseas educational institutions (IBO, Cambridge) for authorization, enrollment, license, and registration fees. The assessee argued these payments weren't royalty for trademark use and no TDS was required under section 195. The ITAT held that without analyzing the basis of invoices raised by overseas institutions and the discount offered, it cannot be concluded whether payments qualify as royalty. The matter was restored to the AO to determine the actual nature and basis of the lump sum fees charged by overseas entities. Case-Laws Income Tax Fri, 08 Mar 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=450749