The Tribunal following the earlier year held that the amount paid by the assessee is not chargeable under article 12 of DTAA because no service were ‘made available’ to the assessee by the service providers. The Tribunal deleted the disallowances. (AY. 2006-07)
CEVA Freight India (P) Ltd. v. Dy. CIT (2018) 192 TTJ 887/ 172 DTR 55 (Delhi)(Trib.)
S. 40(a)(i) : Amounts not deductible – Deduction at source -Non-resident – The administrative fee paid to EGC of US and EGC of Singapore -Not liable to deduct tax at source – DTAA-India – [ Art. 12 ]