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CTBT Pvt. Ltd., In Re (2021) 435 ITR 157 / 280 Taxman 83 (AAR)

S. 195 : Deduction at source-Non-resident-Social Security contribution, Insurance, Relocation cost, etc., Reimbursement cost-Not fee for technical services-Not liable to deduct tax at source-Administration fee liable to deduct tax at source-DTAA-India-Swiss Confederation. [S. 9(1)(vii), Art. 12(4)]

AAR held that;

  1. The social security, insurance, relocation expenses which are in. the nature of committed and obligated payments are in the nature of reimbursements and not for fee for technical services.

 

  1. As admitted by learned authorized representative, the administrative fee paid to KRP was liable for tax deduction at source under section 195 as fees for technical services.