Assessee contended that it was evident from Form no. 15CB that remittance was made towards legal consultancy which did not involve technical services and, hence, payment was business profit covered under article 7 of DTAA between India and UK and, thus, no TDS was to be deducted on same. Matter remanded to Assessing Officer for afresh consideration. (AY. 2011-12)
Vardhman Shipping (P.) Ltd. v. (2022) 197 ITD 250 / 98 ITR 3 (SN) (Ahd.) (Trib.)
S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident-Legal services-Matter remanded-DTAA-India-UK. [S. 9(1)(i), 9(1)(vii), 195, Art. 7]