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NRI TDS related

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11 October 2008 our company sent some pilots to outside india for taking pilots training. and now company is paying the bills for pilots training fee to NRI company at outside india in foreign exchange.

so is there TDS liability or not?
can pilots training fee can be considered as fee for technical service as per section 9 vii of income tax act

what about DTAA?

11 October 2008 in my opinipon , the payment is liable to tds as this is payment for technical services.



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