This discussion concerns whether withholding tax should be applied to additional charges for machine runoff costs incurred when testing machinery before delivery from a non-resident vendor. The suggestion is to deduct 10% withholding tax under Section 195, classifying these charges as fees for technical services.
Company has purchased a machine from Non resident vendor. Non resident vendor has charged the invoice as additional cost towards machine runoff as company has wanted to test the machines before delivery.
Whether tax should be withheld on those machines ?