TDS u/s 195 not deductible on payment of training fees

Infosys BPO Limited Vs DCIT (ITAT Bangalore)

Held that the training fee paid by the assessee to a professional trainer doesn’t amount to Fees for Technical Services and hence TDS u/s 195 not deductible

Facts-

The assessee is a company engaged in the business of rendering BPO services. The assessee made payment of 2100 US$ to a non­resident viz., Stakeholder Centered Coaching (International Ltd.,) hereinafter referred to as the ‘non-

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