Management Fee Disallowed Under Income Tax Act Sec 40(a)(i); Services Deemed Managerial, Not Technical, Per India-UK DTAA.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....TDS u/s 195 - Disallowance of management fee paid by invoking the provisions of section 40(a)(i) - whether payment of management fees cannot be regarded as fees for technical services as per the DTAA between India and the U. K. - For ascertaining chargeability to tax reference to the relevant DTAA is essential - we hold that the assessee’s services were managerial in nature and not technical services. Hence, the assessee is not liable to deduct TDS on the same. - AT....