Dtaa

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sathya (Querist)
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28 December 2016 Sir,
A is parenting company situated at India ,B Is subsidiary company situated at Singapore . A is paying money to B for the purpose of purchase software in CD form ( not a royalty fees ) it is for internal use , & prepackaged software

whether A is liable to deduct TDS
Which DTTA article applies for this type of payment.

ND (Expert)
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28 December 2016 This transaction is subject to TDS. A will have to deduct at source on this payment. The benefit of DTAA can be taken . It will be payment for fees for technical services. It will also be subject to deposit of service tax under reverse charge.