Payments to Gensler-USA for project-specific designs not considered "Royalty" under Indian tax law, TDS section 195. No withholding tax.

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....TDS u/s 195 - P.E. in India - The payments made by assessee to Gensler-USA were merely for project specific drawings & designs without transfer of technology or know-how or even title in drawing & designs - not in the nature of “Royalty” or “Fee for Technical Services”. - AT....