Dismissing the appeal of the revenue the Tribunal held that ;Professional fees paid to foreign company to know about tax law applicable in that Country could not be taxed in India as per Art 14 of the OECD Model Tax Convention hence not liable to deduct tax at source .(AY. 2006 -07 to 2008-09)
ACIT v. Deloitte Haskins & Sells. (2018) 170 ITD 267 / 196 TTJ 355/ ( 2019) 174 DTR 289(Mum) (Trib.)
S. 40(a)(i) : Amounts not deductible – Deduction at source -Non-resident –Professional fees paid to foreign company to know about tax law applicable in that Country could not be taxed in India as per Art 14 of the OECD Model Tax Convention hence not liable to deduct tax at source.