No TDS for use of franchisee infrastructure facilities

The Delhi I-T Tribunal has held that no tax shall be deducted at source under section 194-I in respect of the amount remitted to the franchisees for use of infrastructure facilities. The assesseecompany was engaged in the business of providing computer education and training, through its own centres and also through franchisees. The franchisee was required to provide the infrastructure facilities, like classroom facility, equipment, furniture, fixture and administrative set-up, against which the franchisee received infrastructure claims as per the agreement