TDS u/s 195 not deductible on payment of training fees

Infosys BPO Limited Vs DCIT (ITAT Bangalore) Held that the training fee paid by the assessee to a professional trainer doesn’t amount to Fees for Technical Services and hence TDS u/s 195 not deductible Facts- The assessee is a company engaged in the business of rendering BPO services. The assessee made payment of 2100 US$ to a non­resident viz., Stakeholder Centered Coaching (International Ltd.,) hereinafter referred to as the ‘non-resident’. The non-resident was a tax resident of Hongkong. It is body corporate registered in Hongkong. It is undisputed that there was no Treaty for avoida...