Dismissing the appeal of the revenue the Court held that, payment being not fees for technical services the assesse is not liable to deduct tax at source. ( AY. 2009 -10)
CIT v. Mira Exim Ltd. (2018) 400 ITR 28 (Delhi) (HC)
S.40(a)(ia):Amounts not deductible – Deduction at source – Payment being not fees for technical services ,not liable to deduct tax at source -DTAA-India –Canada [ S.9(2), Art 12 ]