India-UK Tax Convention: SIPCL Payments Taxed in India Despite No Permanent Establishment Claim Under Article 5; Section 195 Applies.

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....Double Taxation Avoidance Convention between India and UK – Cost Contribution Agreement (CCA) with SIPCL - payment received by SIPCL is chargeable to tax in India and the declaration provided by SIPCL that it does not have a Permanent Establishment (PE) in India in terms of Article 5 of DTAC, we rule that the applicant is under obligation to withhold tax u/s 195 of the Act..... - AAR....