‘Loan Arranger Service’ not liable for Deduction of TDS U/s. 195

Brief Facts: The assessee (Idea Cellular Limited) had entered into “Term Loan Facility Agreement” dated 10th September, 2009, as borrower, with Finnish Export Credit Ltd., who is the lender. The HSBC, Hongkong had arranged for the loan as “Arranger” and UK based Company, HSBC Bank, PLC acted as a facility agent. Pursuant to the said agreement dated 10-9-2009, the assessee was liable to pay Arranger’s fees to HSBC, Hongkong (“Arranger”) amounting to Rs. 2,64,75,645/-. The assessee, out of abundant caution remitted the said amount payable as Arranger’s fees after deducting tax @2...