The Assessee, an Association of Persons (AOP) engaged in providing technical expertise in oil exploration and refinery, made payments to its member companies for the salary expenses and other benefits of seconded employees without deducting TDS. The Assessing Officer held that the reimbursements constituted fees for technical services as per Explanation 2 to section 9(1)(vii), making TDS deductible under section 194J for resident secondees and section 195 for non-resident secondees and payments to foreign agents. CIT(A) deleted the disallowance. On appeal the Tribunal held that, reimbursements for Indian salary and other benefits to member companies were not fees for technical services within the meaning of Explanation 2 to section 9(1)(vii), hence TDS was not deductible.  Payments made to resident secondees did not require TDS under section 194J as there was no employer-employee relationship between the Assessee and the secondees.  Payments made to non-resident secondees were not chargeable to tax under section 5(2)(b) as the services were rendered outside India, thus no TDS was required under section 195.  Payments to foreign agents did not attract TDS under section 195 as there was no business connection in India, and the agents did not perform any operations in India.  The Tribunal also held that levy of interest is not barred by limitation. (AY 1996-97 to 1998-1999)