TDS not deductible as reimbursement to member companies by PII doesn’t qualify as fee for technical service

ITO Vs Petroleum India International (ITAT Mumbai)

ITAT Mumbai held that reimbursement of Indian salary and other benefits to the member companies by PII pertaining to all seconded personnel, technical personnel whether posted in India or overseas is not fee for technical services within the ambit of definition of explanation 2 to section 9(1)(vii) of the Act. Hence, TDS not deductible.

Facts- The assessee M/s. Petroleum India International (PII) is an Association Of Persons (AOP) and is assessed as s

Please become a Premium member. If you are already a Premium member, login here to access the full content.