Section 195 TDS not deductible on management fees paid to France entity

Steria (India) Ltd. Vs. ACIT (ITAT Delhi) Ground number 11 is with respect to the disallowance of management services fees for non-deduction of tax u/s 40 (a) (i) of the act amounting to ₹ 206,044,024 incurred on account of management services fees, held to be fees for technical services on which tax deduction at source u/s 195 of the act should have been done by the assessee and therefore disallowance was made. The learned dispute resolution panel also upheld the order of the learned assessing officer holding that payment made to groupe Steria SCA France is also in the nature of fees for te...