10% TDS Applicable on Payment to FSII for Availing Pilot training, rules ITAT

Reliance Commercial Dealers Limited Vs CIT (ITAT Mumbai) Facts- The assessee is a company engaged in the business of Air Transport of Passengers and is a holder of Non-Scheduled Air Transport (Passenger) Services (NSOP) permit granted by the Director General of Civil Aviation / Ministry of Civil Aviation. During the Financial Year 2015-16, the assessee had made payment of USD 61,200 (amounting to Rs.40,30,020) to Flight Safety International Inc, USA for availing training of pilots. However, in the absence of PAN of deductee, the assessee deducted tax at being grossed up rate of 20% under Secti...