No section 195 TDS on Charges for Services for issuance of GDR

CIT Vs Indusind Bank Ltd (Bombay High Court) The issue under consideration is whether the services in relation to issuance of GDRs are covered under the provisions of Section 9(i)(vii) and whether the same liable for TDS under the provisions of Section 195 of the Act? High Court states that services rendered by Amas Bank were purely of a commercial nature and bore the character of income arising to it wholly outside India, emanating from commercial services rendered by the Bank in the course of carrying on of its business wholly outside India. Such services were neither rendered in India nor ...