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2014 (7) TMI 255 - AT - Income TaxAddition u/s 40(a)(ia) – Payment to overseas institution as fees for awarding the degrees, supplying books and course material –TDS not deducted u/s 195 - technical know-how or technical services - Held that:- CIT(A) rightly of the view that the amount has been paid by the assessee to the overseas institutions as fees for awarding the degrees, supplying books and course material - fees is paid towards the study curriculum which includes teachers textbooks, teaching aids, associated marketing tools and materials etc. - There is no transfer of any technical know-how or technical services - The Revenue has not been able to substantiate its plea, as to how the amount paid falls in the category of technical fee – thus, there was no infirmity in the order – Decided against Revenue.
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