TDS not deductible on payment by Deolitte India to Deolitte UK for global brand/communication/technology/knowledge

Deloitte Haskins & Sells LLP Vs DCIT (ITAT Mumbai) The sole issue which permeates in all the appeals is, whether the appellants were liable to deduct tax at source under Section 195 of the Act on the payments made to Holdings by treating it to be Royalty under Article 13(3) of the India-UK DTAA. As noted above, Deolitte Global Holdings has been incorporated by DTTI to facilitate attainment of various objectives to further international alignment, co-operation, cohesion and professional standards of highest quality amongst its member firms, such as the appellants herein. It incurs expenses ...