Company not liable for TDS on managerial services to subsidiaries under IP license agreement.

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....The assessee provided managerial services to its subsidiaries, ancillary to the enjoyment of intellectual property as per the license agreement. The CIT(A) rightly held that such services did not constitute 'technical services', and the assessee was not liable to deduct TDS for managerial services rendered during the assessment years 2010-11 to 2015-16. Regarding short credit of TDS, the Tribunal remanded the issue to the Assessing Officer for verification and granting TDS credit in accordance with law, subject to the assessee complying with the proceedings and furnishing supporting documents.....