Dismissing the appeal of the revenue the Tribunal held that, services rendered by non residents are independent personal services outside India hence the assesse is not liable able to deduct tax at source. (AY. 2011-12)
DCIT v. Hydrosult Inc. (2019) 175 ITD 525 (Ahd) (Trib.)
S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident–Independent personal services outside India-Not chargeable to tax in India –Not liable to deduct tax at source-DTAA–India–Canada. [S.9(1)(i), Art. 12, 14 ]