Cross-border service fees for derivative trading are income of recipient bank; payer not liable under Section 195 for TDS

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....ITAT held that cross-border service fees between Bank A and Bank B relating to derivative trading constitute charges for services rendered to each bank's clients and were correctly treated as income of the recipient bank; the Assessing Officer erred in characterizing payments made by Bank B to Bank A as income of Bank B and in treating Bank B as in default for non-deduction of tax at source under section 195. The impugned additions were found without merit, and the AO was directed to delete those additions. All effective grounds raised by the assessee were allowed, resulting in complete relief on the TDS and income-characterisation issues.....