Revenue Shared With Franchise Doesn't Attract TDS Liability U/S 194-I If No Actual Services Were Rendered: Delhi ITAT

The Delhi ITAT ruled that revenue shared under a franchise agreement does not attract TDS liability under Section 194-I of the Income Tax Act if no actual services are rendered. The tribunal clarified that TDS is applicable only when there is a service component involved. This ruling provides clarity on the applicability of TDS in franchise agreements, ensuring that businesses are not unfairly burdened with tax liabilities in the absence of actual services.