TDS Rate on subcontracting charges paid to Chinese subsidiary will be 10% instead of 20% under Indo-China DTAA

Infosys Limited Vs DCIT (ITAT Bangalore) Conclusion: The applicable rate of TDS on subcontracting charges paid to Infosys China should be considered at 10% as per the India-China DTAA instead of 20% as per section 206AA. Held: Assessee was an Indian company, engaged in the business of development and export of computer software and related services. Infosys China was a company incorporated in China. It was a wholly owned subsidiary of the assessee. Pursuant to sub- contracting agreement, assessee sub-contracted certain overseas work in China to Infosys China. During the year under consideratio...