TDS Not Applicable on Purchases from AEs; Assessee Entitled to DTAA Benefits, No Disallowance u/s 40(a)(i.

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....TDS u/s 195 - As disallowance u/s 40(a)(i) is in respect of purchases made from the AEs, which is in no manner connected with the Commission segment, we hold that the assessee is entitled to the benefit provided by article 24 of the DTAA and cannot be visited with the disallowance u/s 40(a)(i) - AT....