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TDS not deductible on payment to non-resident for availing General Business Support Service: Bombay HC
Case Law Details
- Case Name
- Shell India Markets Private Limited Vs Union of India (Bombay High Court)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Courts
- All High Courts, Bombay High Court
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Shell India Markets Private Limited Vs Union of India (Bombay High Court)
Bombay High Court held that payments made to non-resident for availing General Business Support Service under Cost Contribution Arrangement is not in the nature of fees for ‘technical services’ and accordingly tax is not deductible on the same.
Facts- This Petition visits the question pertaining to determination of tax liability of the payments made by Petitioner to its non resident group company, Shell International Petroleum Company Limited (SIPCL) for availing General Business Support Services (BSS) under a Cost C...





