Case Law Details
Case Name : KPMG India Private Limited, Vs DCIT, Cir 6(2), Mumbai (ITAT Mumbai)
Related Assessment Year : 2001-2002
Courts :
All ITAT ITAT Mumbai
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Looking to the nature of professional services rendered to the KPMG USA, it is evident that it does not fall in any of the terms of definition given for Royalty under Article 12 of Indo US DTAA. It was purely a professional service for consultancy which were rendered outside India and nor for supply of scientific, technical, industrial or commercial knowledge or information. Thus, nature of payment do not fall within the meaning of Article 12 and, therefore, there was no liability to deduct TDS and consequently disallowance made under section 40
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