Very urgent tds query

Hi it depends on the permanent establishment,however if its the case of technical services or royalty,tax must be witheld,therefore in your case tax wil be deducted for payments made to subsidiary,and second point indian company is anyway liable to tax in india

regards

sripal jain

Royalties and fees for technical services.

Tax is withheld from royalties and fees for technical services paid to foreign companies by Indian concerns (under post-March 31, 1976 agreements that are either approved by Indian government or in accordance with declared industrial policy) at 30 percent on the gross amount or a lower treaty rate (see Appendix IV). Some treaties exempt fees for technical services rendered abroad or specifically provide for deduction of expenses.

therefore subsidiary must deduct tax is point of view of argentina rules,however indian company is taxed