Dy. CIT v. Aspire Systems India P. Ltd (2024) 115 ITR 26 (SN) (Chennai)(Trib)

S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident-Installation and testing service-Fees for technical services-Not liable to tax in India-Not liable to deduct tax at source.[S.9(1)(vii)(b), 195]

Held that  payment of  installation and testing service paid to non-resident is   not liable to tax in India hence  not liable to deduct tax at source.(AY. 2015-16)

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