Non-resident business profits not taxable in India without Permanent Establishment, per Section 195 of Income Tax Act.

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....TDS u/s 195 - in the absence of the PE in India, the business profit of the non-resident is not taxable in India. - even if it is considered that the payments made to non-resident will fall under Article 22 of the Treaty viz. “Other Income“, then also not taxable in India - AT....