TDS not deductible u/s 195 as services utilised outside India: ITAT Delhi

QAI India Ltd Vs DCIT (ITAT Delhi) ITAT Delhi held that income of non-resident is not liable for deduction of tax at source u/s. 195 as amount paid is covered in exception provided in section 9(1)(vii)(b) of the Income Tax Act since project has been carried outside India and services are utilised outside India. Facts- The assessees company is a limited company engaged in the business of Software development. The company provides the software related services such as software designing engineering, software training and consultancy services. Certification and management services. The matter inv...