TDS not deductible on payment to non-resident having no PE in India for services rendered outside India

Turbo Energy Private Limited Vs DCIT (ITAT Chennai)

The AO held that the payments were made for managerial services and taxable u/s. 9(1)(vii) of IT Act. Since the assessee failed to deduct the tax at source u/s. 195 of the IT Act, disallowed the payments u/s.40(a)(i) of IT Act. The Ld. CIT(A) deleted the addition finding that the services rendered by non-resident do not fall under managerial or technical services within the meaning of IT Act and the services are rendered outside India and non-resident party has no permanent

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