ITAT directs CIT(A) to decide appeal on merits observing principle of natural justice

Toshiba JSW Power Systems Private Limited Vs DCIT (ITAT Chennai) The AO had held that payment made by the assessee to non-resident towards cost of salary of seconded employees is fees for technical services as per section 9(1)(vii) of the Act and also as per Article 12(4) of India & Japan DTAA and held to be liable to tax @ 10% of gross amount on fee for technical services. It was the contention of the assessee before CIT(A) that reimbursement of cost of salary to seconded employees is not fees for technical services and thus, assessee is not liable to deduct TDS as required u/s. 195 of th...