Guarantee Fee paid by assessee to its Dutch Associate Enterprise is neither FTS nor Interest under DTAA; TDS u/s195 not applicable.
This tax alert summarizes the recent ruling given by Income Tax Appellate Tribunal, Delhi branch, which rules that TDS u/s. 195 is not applicable on payment of corporate guarantee fees by assessee [an Indian Co.] to its Dutch holding co. [AE] during AYs 2009-10 & 2010-11 and held that guarantee fee neither partakes the nature […]