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 such having main object and activity is to provide technical expertise in the field of oil expl...