The assessee was a tax resident of Singapore and provided management advisory services. The assessee entered into an agreement with its Indian subsidiary to provide advisory services in the field of management, sales, marketing, finance and administrative, human resources and information technology. For such services to the Indian company, the assessee in the previous year relevant to the assessment year 2014-15 earned management fee of Rs. 32,23,41,117/-. The AO held that the management fee received by the assessee from the Indian entity was in the nature of fees for technical services under the Double Taxation Avoidance Agreement between India and Singapore taxable in India at 10 per cent. Accordingly, he proposed a draft assessment bringing to tax the management fee received by the assessee and also levied interest DRP upheld the decision of the AO. On appeal the Appellate Tribunal held that that the liability to pay advance tax was not on the non-resident as the liability was on the payer to deduct tax at source under section 195 of the Income-tax Act, 1961 while making such payment. Therefore interest under section 234B was not chargeable (AY. 2014-15)