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of TDS u/s 195 - for providing standard bandwith services - royalty or business income - The amount received by RJIPL from the assessee for providing standard bandwith services could not be characterised as ‘royalty’ as per the India- Singapore DTAA, and was in fact the “business profits”, which is not taxable as RJIPL did not have any business connection or a PE in India - No TDS
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