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Sum paid to Swiss Co. for testing services not taxable as FTS in absence of any transfer of technology

January 9, 2019[2019] 101 136 (Ahmedabad - Trib.)

IT/ILT : Where assessee made payment to a Swiss based entity for testing services without deduction of tax at source, in view of fact that services were simply testing services which did not involve any transfer of technology, it was to be held that assessee did not have any tax withholding obligations from payments made to Swiss entity and accordingly there could have been no disllowance under section 40(a)(i) for non-deduction of tax at source under section 195

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