LIMITED LIABILITY PARTNERSHIP registered at Delaware state at USA

[Joseph Renji]

Can  a LIMITED LIABILITY PARTNERSHIP registered at Delaware state at USA be considered as a company or Body corporate for taxation purposes in India, vide section 2 (17) (ii) of the IT Act for the purpose of deducting tax at source under section 195 of the IT Act. 

The LLP is a legal firm at USA, and the payments are made to the firm for conducting a case that was originated and is being conducted at USA. No benefit, services,or goods accrue or arise in India as a result of the conduct of this case at USA. Therefore is the tax to be deducted at source on the payments of fees to the US attorneys through foreign remittances through bank.