https://www.taxtmi.com/caselaws?id=777249 ITAT (Hyderabad) held that payments to a foreign service provider (tax resident of Australia) for business support services were not taxable as FTS and, given treaty/residence benefits under s.90(2), the AO's disallowance under s.40(a)(i) for non-deduction of TDS u/s 195 was deleted. On transfer-pricing, the Tribunal treated overdue receivables from associated enterprises as international transactions requiring benchmarking; it directed imputation of interest using LIBOR plus 200 bps (not SBI-PLR). Netting of receivables/payables was allowed only if detailed AE-wise data is furnished. Grounds were partly allowed. en-us Fri, 22 Aug 2025 00:00:00 +0530 Wed, 27 Aug 2025 08:41:02 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=777249 ITAT (Hyderabad) held that payments to a foreign service provider (tax resident of Australia) for business support services were not taxable as FTS and, given treaty/residence benefits under s.90(2), the AO's disallowance under s.40(a)(i) for non-deduction of TDS u/s 195 was deleted. On transfer-pricing, the Tribunal treated overdue receivables from associated enterprises as international transactions requiring benchmarking; it directed imputation of interest using LIBOR plus 200 bps (not SBI-PLR). Netting of receivables/payables was allowed only if detailed AE-wise data is furnished. Grounds were partly allowed. Case-Laws Income Tax Fri, 22 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=777249