Section 195 TDS not to be deducted on routine support services as it is not FTS under India UK DTAA

M/s B.G. India Energy Solutions P Ltd Vs DCIT (ITAT Delhi) Conclusion: Where services provided by employees of BGIL were merely in the nature of routine support services, the same could not be termed as ‘FTS’ under Article 13 of the India UK DTAA, therefore, there was no requirement for assessee to deduct taxes from such payments in India u/s 195. Held: In the instant case, assessee-company claimed an amount that was in the nature of provision for ‘time writing charges’ based on estimated time cost of employees of assessee-company’s sister concern BGIL. AO held that TDS had not been ...