ITO (IT) v. Hartaj Sewa Singh. (2025) 211 ITD 179 (Kol) (Trib.)

S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident-Payment of advisory fee to a foreign company-Not fees for technical services-Not liable to deduct tax at source-DTAA-India-Singapore. [S. 9(1)(vii), 195, Art. 12]

Held that payment of advisory fee to a foreign company for arranging loan for it from foreign establishments and non-resident financiers with their efforts from Singapore, payment of such advisory fee could not be termed as royalty or fee for technical services as it was in nature of commission for financial services rendered. Not liable to deduct tax at source.(AY. 2012-13)

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