TDS u/s 195 not deductible as payment doesn’t qualify under fees for technical service

Hindustan Aeronautics Limited Vs DCIT (ITAT Bangalore) ITAT Bangalore held that payment made towards service charges to CGTM France doesn’t fall under the category of ‘fees for technical service’. Accordingly, TDS u/s 195 of the Income Tax Act not deductible. Facts- M/s. Hindustan Aeronautics Limited (HAL) having its registered office at Bangalore, is engaged in the business of design and development of engines of flights & helicopters. HAL entered into an agreement with Turbomeca for designing Dhurve/Shakti engine. The Shakti engine was co-developed by Turbomeca (company based at Fr...