Non-deduction of TDS u/s 195 on AMC: Non-resident payee's income not taxable in India without PE.

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....TDS u/s 195 - Non-deduction of TDS on AMC contract - It is not the case of AO that the non-resident payee had any PE in India and, therefore, the business income in the hands of non-resident payee could not be taxed in India. - AT....