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Payments for rework, segregation and repackaging: whether routine work is 'technical services' triggering TDS u/s195-disallowance deleted
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....The dominant issue was whether payments for rework, segregation and repackaging attracted TDS under s.195 as "fees for technical services" under Expl. 2 to s.9(1)(vii). The tribunal held that the activities were routine and standardized, performed manually or mechanically on predetermined specifications, and did not involve specialized expertise or any new scientific process; the Revenue also did not dispute the nature of work. Consequently, the deletion of the disallowance was affirmed and the Revenue's appeal was dismissed. - ITAT....