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2016 (4) TMI 953 - ITAT MUMBAI

2016 (4) TMI 953 - ITAT MUMBAI - [2016] 49 ITR (Trib) 70 - TDS u/s 195 - Disallowance u/s. 40(a)(i) - professional fees paid outside India without deduction of tax at source - existence of PE in India - Held that:- Looking into the nature of services rendered. It is seen that, firstly, none of these services fall in the nature of ‘make-available’ of any technical knowledge, experience, skill, know-how or process. The provisions of Indo-U.S. and U.K. treaties are absolutely clear that in case of .....

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also for a very less period. Therefore, such a payment does not attract the provisions of TDS under section 195. See KPMG vs JCIT [2013 (11) TMI 188 - ITAT MUMBAI] - Decided in favour of assessee - Disallowance made by the AO u/s 40a(i) in respect of professional fee paid to KPMG Huazhen, China - Held that:- No law can create an obligation to deduct tax at source by retrospective operation. Thus, in our considered view, the assessee was not required to deduct tax at source on the said paymen .....

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d by resident of a contracting state in respect of professional services or other activities of an independent character shall be taxable only in that contracting state except when the said resident has a PE or fixed basis or stay exceeding prescribed number of days in the other contracting states. It is noted on the basis of facts brought before us that these professional services have been provided in China by a team consisting of accountants, lawyers and engineers. Thus, we find that these se .....

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avla and Shri Harsh Kakadia (AR) For The Revenue : Shri Ramapriya Raghavan, (DR) ORDER Per Ashwani Taneja (Accountant Member): These are cross appeals pertaining to the same assessee for A.Ys. 2007-08 & 2008-09. Since identical issues are involved, these were heard together and disposed by this common order for the sake of convenience. 2. During the course of hearing, arguments were made by Shri Paras Savla & Shri Harsh Kapadia, Authorised Representative (AR) on behalf of the Assessee an .....

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in deleting the disallowance of ₹ 1,22,58,136/- u/s. 40(a)(i) being professional fees paid outside India without deduction of tax at source. 4. The brief facts are that during the year under consideration the assessee was engaged in the business of rendering taxation, business advisory, audit related services and other consultancy services. 4.1. During the course of assessment proceedings it was noted by AO that assessee had paid fee for professional services outside India without deducti .....

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ble, consequently no disallowance could be made u/s 40(a)(i) of the Act. The assessee also submitted that the aforesaid payments were governed by provisions of Double Taxation Avoidance Agreement (DTAA) entered between India with UK, USA, France and China. KPMG was Limited liability registered in UK and income of KPMG was taxable as income of the partner's of KPMG LLP. The partner's in KPMG LLP were individual resident in the UK as per the treaty. KPMG LLP did not have fixed basis /estab .....

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KPMG, Huazhen was a company registered in China as per treaty. The services were rendered in China. The income from services was not taxable in India; consequently, no withholding of tax was required. 4.3. The AO examined the submissions of the assessee, but did not find it acceptable. The AO observed that the services rendered by non-residents were in the areas of application of high level of skills as well as technical and industrial know-how. The AO noted that the assessee emphasized on make .....

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f UK DTAA. In support of his view, the AO relied upon the case of Raymond Ltd. vs DCIT [2003] 86 ITD 791 (Mum) and Hindalco Industries Ltd. vs ACIT 94 ITD 242. It was further stated that the assessee did not take any approval of remittance as per provisions of section 195 or 197 of the Act. The AO also relied upon the cases of Transmission Corporation of A. P. Ltd. v CIT 239 ITR 587(SC) and CIT v Samsung Electronics Co. Ltd. [2010] 320 ITR 209 in support of his contention. 4.4. In the light of a .....

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ed u/s 195 of the Act. The assessee made detailed submissions before Ld. CIT(A) to argue that these payments were not subject to TDS provisions u/s 195 for various reasons. The assessee relied upon the various judgments in support of its detailed arguments. The assessee also submitted that similar issue in assessee s own case was decided in favour of the assessee by the Ld. CIT(A) in assessee s own case for A.Y. 2004-05. The Ld. CIT(A) considered submissions of the assessee in detail and decided .....

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the relief given by the Ld. CIT(A) for the above mentioned three parties, whereas assessee filed an appeal before the Tribunal with respect to the fourth party i.e. KPMG, Huazhen (China) for which relief was not granted by the Ld. CIT(A). During the course of hearing before us, Ld. DR has relied upon the orders of the AO. On the other hand Ld. Counsel of the assessee argued the matter in detail and in addition to relying upon the order of the Ld. CIT(A), it was submitted by him that these issues .....

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ce, know-how or process: In order to constitute fees for technical services under the DTAA, mere provision of services is not enough, the services should also make available technical knowledge, skill, experience, know-how or process. To fit into the terminology "making available", the technical knowledge, skill, etc., must remain with the person receiving the services even after the particular contract comes to an end. It is not enough that the services offered are the product of inte .....

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ervice that may require technical knowledge, skills, etc., does not mean that technology is made available to the person purchasing the service, within the meaning of the DTAA. In support of the above said propositions, Ld. Counsel has placed reliance on the following judgments: 1. KPMG v JCIT 33 taxmann.com 23 (Mum) 2. NQA Quality Systems Registrar Ltd. v DCIT 2 SOT 249 (Delhi) 3. Invensys Systems Inc., In re 183 Taxman 81 (AAR) 4. CIT v. De Beers India Minerals (P.) Ltd. 21 taxmann.com 214(Kar .....

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nt personal services' within the meaning of article 15, the same shall automatically be out of ambit of article 12(4) since, in view of the specific provisions of article 12(5), notwithstanding the provisions of article 12(4), 'fees for included services' do not, inter alia, include amounts paid to any individual for independent personal services as defined in article 15. In other words, when an amount paid to an individual or a firm resident in the contracting state, is found to be .....

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nd mutually exclusive. In support of this proposition he has relied upon the following judgments: 1. Graphite India Ltd. v. DClT 86 ITD 384 (Kol) 2. DClT v. Chadbourne & Parke LLP (2 SOT 434 (Mum) It was further submitted that once the services in question constituted 'professional services', the natural corollary to this finding is that the provisions of article 15 were to be applied, which specifically dealt with professional services. The provisions of article 15, being specific p .....

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fiscal year or he has a fixed based regularly available to him in India for performing such activities. In other words, the remuneration paid would be outside the scope of fees for technical services, if they were in the nature of fees for professional services and consequently would be taxable in India only if conditions stipulated in article 15 were complied with. In support of this proposition, Ld. Counsel has relied upon following judgment: 1. Maharashtra State Electricity Board v. DCIT 90 .....

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0, with retrospective effect. The effect however, as far as withholding of tax liability is concerned, depends on the law as it existed at the point of time when payments were made from which taxes ought to have been withheld. A retrospective amendment in law might change the tax liability in respect of an income, with retrospective effect, but it cannot change the tax withholding liability, with retrospective effect. Since the subject services were rendered outside India, the same were not subj .....

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. DCIT v. Virola International 42 taxmann.com 286 (Agra ITAT) 6. Sterling Abrasives Ltd. v. ITO ITAT No.2243 & 2244/Ahd/2008 (Ahd) 7. Metro & Metro v. ACIT 39 taxmann.com 26 (Agra ITAT) 8. Infotech Enterprises Ltd. v. ACIT 41 taxmann.com 364 (Hyderabad ITAT) 9. Sonata Information Technology Ltd. v. DCIT 25 taxmann.com 125 (Mumbai ITAT) 4.7. We have gone through all the arguments made before us by both the sides, orders of the lower authorities as well as judgments placed before us. 4.8. .....

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have been provided outside India and these were of the nature of audit and/or advisory services. It is seen that none of the services was had the attributes of making available of any technical knowledge, experience, skill, know-how or process. The relevant provisions of treaties with these countries stipulate that in case of FTS, it is mandatory that technical knowledge etc. should be made available to the recipient of services and the said recipient should be free to use it in its own right. .....

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hese payments fall within the definition of independent person service as provided in respective DTAAs, mostly in Article 15, under which, the payment in the hands of a payee can be taxed in India only if provider of the services stays in India for a period aggregating to 90 days or more during the relevant financial year or if the said person has a PE (Permanent Establishment) or fixed basis regularly available to him in India for performing such activities. It is noted from the facts of this c .....

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tory condition that services should be rendered in India before it could be made taxable u/s 9(1)(vii). This requirement of rendering services in India was done away with insertion of an explanation by the Finance Act, 2010, with retrospective effect. But the issue that arises here is that even if a retrospective amendment may legally change the determination of tax liability in the hands of recipient of income with the retrospective effect, but whether it can also create an obligation upon the .....

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e Court, in the case of Ishikawajima Harima Heavy Industries Ltd Vs DIT (288 ITR 408), had held that in order to bring a fees for technical services to taxability in India, not only that such services should be utilized in India but these services should also be rendered in India. Analyzing this legal position, Hon ble Bombay High Court has, in the case of Clifford Chance Vs DCIT (318 ITR 237), observed as follows: "The apex Court had occasion to consider the above question in the case of I .....

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its plain sense, as per the apex Court it requires two conditions to be met-the services which are the source of the income that is sought to be taxed, has to be rendered in India, as well as utilized in India, to be taxable in India. Both the above conditions have to be satisfied simultaneously. Thus for a non-resident to be taxed on income for services, such a service needs to be rendered within India, and has to be part of a business or profession carried on by such person in India. In the ab .....

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isions of the DTAA. What is relevant is receipt or accrual of income, as would be evident from a plain reading of s. 5(2) of the Act subject to the compliance with 90 days rule. As per the above judgment of the apex Court, the interpretation with reference to the nexus to tax territories also assumes significance. Territorial nexus for the purpose of determining the tax liability is an internationally accepted principle. An endeavor should, thus, be made to construe the taxability of a nonreside .....

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have sufficient territorial nexus with India so as to furnish a basis for imposition of tax. Whereas a resident would come within the purview of s. 9(1)(vii) of the Act, a non-resident would not, as services of a non-resident to a resident utilized in India may not have much relevance in determining whether the income of the non-resident accrues or arises in India. It must have a direct link between the services rendered in India. When such a link is established, the same may again be subjected .....

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India . It is thus, evident that s. 9(1)(vii)(c), read in its plain, envisages the fulfillment of two conditions : services, which are source of income sought to be taxed in India must be (i) utilized in India, and (ii) rendered in India. In the present case, both these conditions have not been satisfied simultaneously." 7. The law laid down by Hon ble Supreme Court, in the case of Ishikawajma-Harima Heavy Industries Ltd. vs. Director of Income Tax (supra), binds everyone under Article 141 .....

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egal position) does no longer hold good in view of retrospective amendment w.e.f. 1st June, 1976 in s. 9 brought out by the Finance Act, 2010. Under the amended Explanation to s. 9(1), as it exists on the statute now, it is specifically stated that the income of the non-resident shall be deemed to accrue or arise in India under cl. (v) or cl. (vi) or cl. (vii) of s. 9(1), and shall be included in his total income, whether or not (a) the nonresident has a residence or place of business or busines .....

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ity in India. 8. It is thus clear that till 8th May 2010, the prevailing legal position was that unless the technical services were rendered in India, the fees for such services could not be brought to tax under Section 9(1)(vii). The law amended was undoubtedly retrospective in nature but so far as tax withholding liability is concerned, it depends on the law as it existed at the point of time when payments, from which taxes ought to have been withheld, were made. The tax deductor cannot be exp .....

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in cash or by the issue of a cheque or draft or by any other mode, whichever is earlier, deduct income -tax thereon at the rates in force . When these obligations are to be discharged at the point of time when payment is made or credited, whichever is earlier, such Assessment year : 2008 -0 9 Page 6 of 7 obligations can only be discharged in the light of the law as it stands that point of time. Section 40(a)(i) provides that, inter alia, notwithstanding anything to the contrary in sections 30 to .....

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nd such deductibility of tax at source, as we have discussed above, has to be in the light of the legal position as it stood at the point of time when payment was made or creditedwhichever is earlier . Clearly, therefore, the disallowance under section 40(a)(i) can come into play only when the assessee had an obligation to deduct tax at source from payments to non-residents, and the assessee fails to comply with such an obligation. In view of these discussions, so far as payments made before 8th .....

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in India. Therefore, the assessee did not have any liability under section 195 r.w.s. 9(1)(vii) to deduct tax at source from these payments. Once we come to the conclusion that the assessee did not have any obligation to deduct tax at source from these payments, in the light of the above discussions and as corollary thereto, no disallowance can be made in respect of these payments. As we have come to these conclusions in the light of the provisions of the domestic law, i.e. Income Tax Act, itsel .....

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ACIT Vs Evolv Clothing Pvt. Ltd [(2013) 33 taxmann.com 309] wherein on the basis of taxability of income alone, the coordinate bench has confirmed the disallowance under section 40(a)(i), we can only say that a decision cannot be an authority for a legal question which has not been dealt with in that decision, or not having been raise d in that case. 10. In view of these discussions, as also bearing in mind entirety of the case, we uphold the conclusions arrived at by the learned CIT(A) and dec .....

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Act, 2010 cannot be pressed into service to create an obligation upon the assessee for deduction of tax at source, which otherwise, was not upon the assessee, as per law existing at the time of making of impuned remittances. 4.12. Further, we find that identical issue had arisen in assessee s own case in A.Y. 2004-05, wherein disallowance was made by the AO u/s 40(a)(i) on the payments made on account of fee paid for professional services to the nonresidents. The Tribunal, vide its order, subse .....

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d by all the persons, it is seen that, firstly, none of these services fall in the nature of make-available of any technical knowledge, experience, skill, know-how or process. The provisions of Indo-U.S. and U.K. treaties are absolutely clear that in case of fees for technical services, it is essential that technical knowledge, skill, know-how should be made available to the assessee and the assessee should be at liberty to use them in its own right. If the service does not result in making avai .....

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duct tax at source only if the sum paid is assessable to tax in India. The obligation to deduct tax is limited to the appropriate proportion of income which is chargeable under the Act and not otherwise. Reliance was placed upon the judgment of Hon ble Supreme Court, in G.E. India Technology Centre (P.) Ltd vs CIT 327 ITR 456, wherein similar observations were made. In view of the detailed discussion, it was held by the Bench that no payments were liable or chargeable to be taxed in India, and t .....

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e s appeal in ITA No.6286/Mum/2012 for A.Y. 2007-08 6. Ground No.1: In this ground the assessee has challenged the action of Ld. CIT(A) in upholding the disallowance made by the AO u/s 40a(i) in respect of professional fee of ₹ 6,00,482/- paid to KPMG Huazhen, China. 6.1. The reasons for upholding the disallowance for Ld. CIT(A) is that since the Indo China Treaty does not have make available clause, therefore the payment can be considered as fee for technical services and therefore, would .....

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ly deal with professional services . Provisions of Article 14, being specific provisions for professional services, will override the relatively general provisions of Article 12, which deals with fees for technical services . Thus, the services (relating to review of information security services & assistance in audit) which were professional services & rendered by a resident of china, would be covered under Independent Personal Services as contemplated under Article 14 of the DTAA and, .....

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TS and accordingly these would not fall in Article 12, and therefore Ld. CIT(A) erred in holding that TDS was required to deducted on the remittances made to KPMG-China. 6.4. We have considered the submissions of the assessee and find that we have discussed this issue already in detail while disposing the appeal of the Revenue as discussed above, in detail. The legislature cannot expect an assessee to do impossible. In our considered opinion, no law can create an obligation to deduct tax at sour .....

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l specifically in article 14 of Indo China Treaty. We have gone through article 14 of the Tax Treaty which provide that income derived by resident of a contracting state in respect of professional services or other activities of an independent character shall be taxable only in that contracting state except when the said resident has a PE or fixed basis or stay exceeding prescribed number of days in the other contracting states. The terms professional services have been defined to include inter .....

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find that these services specifically fall in Article 14, and in absence of their being any PE or any stay of the persons of KPMG China, in India, the payment made by the assessee was not taxable in India and therefore, not liable to deduction of tax at source. The Ld. Counsel has further taken up another argument that for invoking provisions of Article 12(4) of Indo China treaty, it is mandatory that the services must be rendered in India by residents of China, in view of clear provisions of de .....

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,743/- as undisclosed income from professional services on the basis of Annual Information Return. 7.1. We have gone through the facts of the case; it appears that proper details could not be examined by the lower authorities. We find it appropriate to send this issue back to the file of the AO, who shall examine all the details and evidences before deciding this issue and shall give adequate opportunity of hearing to the assessee. 7.2. We shall like to further clarify that no addition can be ma .....

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to grant credit of ₹ 15,05,849/- being the amount of taxes paid in the United Kingdom, the corresponding income whereof was offered to tax in India. 8.1. It has been submitted further that although the assessee has filed a petition u/s 154 before the AO but no relief has been granted show far. The AO has passed the order u/s 154 dated 07.02.2011 wherein the AO has accepted the claim in principle but stated that credit shall be granted after verification of relevant documents. 8.2. This kin .....

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filed by the assessee is partly allowed. We shall take Appeal of the Revenue in ITA No.1918/Mum/2013 For A.Y. 2008-09. 10. The revenue has raised following grounds: On the facts and in the circumstances of the case and in law, whether the Ld. CIT(A) was justified in deleting the disallowance of ₹ 6,68,10,721/- u/s 40(a)(i) being professional fees paid outside India without deducted of tax at source. 11. In this year disallowance was made on account of payment made to the following parties .....

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49,702/- 10) Payment to the Conference Board Inc. USA 74,068/- 11) Payment to KPMG IFRG Ltd. UK 1,78,693/- 12) Payments to KPMG LLP, USA 86,63,354/- 13) Payments made to KPMG USCMG Ltd. UK 5,52,80,313/- 14) Payments made to KPMG International, the Netherlands 5,64,952/- Total 7,06,65,349/ The AO has made disallowance by passing a brief assessment order relying upon its earlier year for A.Y. 2007-08. 11.1. Being aggrieved, the assessee filed an appeal before Ld. CIT(A) and made detailed submissio .....

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acts and law applicable with respect to the services in question and payment made thereof by the assessee. We find it appropriate to reproduce relevant part of order of Ld. CIT(A): 2.3. I have considered the facts and perused the material on record. It is noticed that Rahman Rahman Huq, Bangladesh and KPMG Mauritius are firms of invidividuals registered in Bangladesh and Mauritius respectively. KPMG Portugal, KPMG Sweden, KPMG Netherlands, Background Bureau Inc., USA Scherzer Intl., USA, KPMG IF .....

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cal services in nature and having been rendered outside India, fall outside the purview of Article 12 / 13 of the respective tax treaties, therefore the income fell under the ambit of Article 7 of the respective tax treaties dealing with 'Business Profits'. Since the overseas entities did not have a permanent establishment in India, there was no income chargeable to tax in India and consequently, no requirement of tax withholding. 2.3.1. I also find that payments made by the assessee to .....

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under Article 12 of India-USA tax treaty, even then they do not make available technical knowledge, experience, skill, know-how or processes or do not consist of the development and transfer of a technical plan or technical design by virtue of Article 12(5)(e). Therefore same are not taxable in India. The ARs relied in the case of Maharashtra State Electricity Board v. DCII (2004) 90 ITD 793 (Born) and Clifford Chance, United Kingdom v. DOT (2004) 176 Taxman 458 (Born) which also support their .....

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l95/197of the Act in the tight of ratio of decision in the case of GE India Technology Centre Pvt. Ltd. V CIT 327 11R456 [SC). It is also noticed that similar issue in the case of the appellant has also been accepted by the CIT [A) in appellant's own case for AY 2004-05 and AY 2007-08. Therefore disallowance u/s 40[a)[i) in respect of payment mode to Sidney Austin LLP, USA and KPMG [[F, USA is deleted. 2.3.2.It is also seen that the payment made to The Conference Board Inc. is towards member .....

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in respect of payment mode to The Conference Board Inc. is deleted. 2.3.3. I also find that the payment made to KPMG international towards the usage charges of online database and GTPS interpreter (Transfer pricing database) for the period 01 October 2006 to 30 September 2007 is towards reimbursement of expenses and not towards services. As can be seen from the details the remittance is towards membership fees and not towards services. Thus the question of considering them as 'fees for tech .....

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