Authority for Advance Rulings held In the case of Satyam Computer Services Ltd., that it is trite law that unless the payment made attracts the tax under the Income Tax Act, there would be no liability to deduct tax under Section 195 of the Income Tax Act.
Authority for Advance Rulings held In the case of Measurement Technology Limited, UK that the services under agreement No.1 relate to review by Group operation Director and general guidance given by him on financial, operational, human resource, setting up targets and performance appraisal related matters
Authority for Advance Rulings held In the case of Cummins Limited, UK that the agreement shows that the CTIL, a company incorporated in India is working with the applicant only to ensure market competitive pricing from the suppliers.