Allowing the appeal of the assessee, the Tribunal held that, Payment for providing global support services and no technical Knowledge, experience, skill, know-how, or process made available to the assessee, hence payment is not for technical services. Accordingly the assessee is not liable to deduct tax at Source hence no Disallowance can be made. (AY. 2007-08)
Exxon Mobil Company India P. Ltd. v. ACIT (2018) 65 ITR 583//196 TTJ 1070/ 97 taxmann.com 43 (Mum.)(Trib.)
S. 40(a)(i) : Amounts not deductible – Deduction at source-Non -resident-Payment for providing global support services-No technical Knowledge, experience, skill, know-how, or process made available to the assessee-Payment is not for technical services — Not iiableto deduct tax at Source. — No Disallowance -DTAA-India-Singapore [ S.9(1)(vii),195 ]