TDS not deductible on IT support service in absence of gaining technical knowledge

CPP Assistance Services Pvt Ltd Vs C.I.T (ITAT Delhi) ITAT Delhi held that as there is no gain of technical knowledge, experience or skill, the IT support service do not fall under the definition of FTS under Article 13 of the DTAA and hence TDS not deductible on the same. Facts- During the course of scrutiny assessment proceedings, AO noticed that the assessee has paid an amount of Rs. 5,47,90,000/- to its holding company CPP Limited, UK but has not deducted tax at source claiming that Information Support System Services availed by the assessee company do not fall under the definition of FTS ...