TDS not deductible on Corporate guarantee fee paid to AE based at Netherlands

Lease Plan India Pvt. Ltd Vs DCIT (ITAT Delhi) These appeals are against disallowance made by the learned assessing officer under section 40 (a)(i) on account of non-deduction of tax at source on guarantee commission paid to lease plan Corporation NV Netherland is confirmed holding it to be payment in nature of Fees For Technical Services as well as”Interest as per the article 11 and 12 of The Double Taxation Avoidance Agreement [ DTAA] between India and Netherland. The learned assessing officer held that tax is required to be deducted at source on the above payment under section 195 of The ...