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TDS obligation couldn't be fastened on a person on basis of retrospective amendment

November 6, 2019[2019] 110 311 (Bangalore - Trib.)/[2019] 179 ITD 367 (Bangalore - Trib.)

INTERNATIONAL TAXATION : For assessment years 2007-08 and 2008-09, payment made by assessee airlines to non-resident companies in respect of training of pilots and cabin crew could not be brought to tax as fee for technical services on basis of retrospective amendment to section 9 by insertion of an Explanation by Finance Act, 2010 with retrospective effect from 1-6-1976

INTERNATIONAL TAXATION : Payment of simulator fee made by assessee to non-resident companies was not liable to tax in India as royalty or fee for technical services under Act or under India - UAE DTAA.
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