Payments to Non-Resident Surveyors Under DTAAs Not Taxed u/s 195 Due to Lack of Technical Services.

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....Non deduction of tax at source u/s 195 - the payments made to the non-resident surveyors of countries with DTAAs having ‘make available’ clause or having MFN clause were not taxable as the non-resident surveyor did not make any technical know-how, etc. available to the assessee company. - AT....