TDS not deductible on payment to non-resident translator

Facts :- The Assessing Officer has made disallowance of Rs. 2.63 Crores under Section 40(a)(i) on account of non-deduction of tax at source on the payments made to non­resident translators. The authorities below have held translation services to be technical in nature. On the other hand, the contention of the assessee is that the payment for translation services to non-residents does not fall within the ambit of “fees for technical, managerial or consultancy services”. Held – In the present case, the assessee is getting the translation of the text from one language to another. The o...