TDS u/s 195 - disallowance u/s 40(a)(i) - payment to a foreign...

TDS u/s 195 - disallowance u/s 40(a)(i) - payment to a foreign entity as testing /certification fees outside India - the assessee bonafidely believed that such certification fee was not liable to tax in India, as the same was not covered within the meaning of “ Fee for Technical Services” as provided u/s 9(1) (vii) of the Act and/or the overriding provisions of the Double Taxation Avoidance Agreements stands covered in favour of the assessee - AT