Held that managerial services charges paid to Non-Residents is not liable to tax at source, hence no disallowance can be made. Expenses incurred towards management services allowable as revenue expenditure. (AY.2013-14)
Jt. CIT (OSD) v. Intertek India Pvt. Ltd. (2022)99 ITR 54 (SN) (Delhi) (Trib)
S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident-Managerial services charges paid to Non-Residents not Liable to tax at source-Disallowance is not justified-Expenditure on management services-Allowable as business expenditure. [S. 195]