Appellant Not Required to Deduct Tax on Payment to NPL as No Royalty Under DTAA; No PE in India.

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....Tds U/S 195 - Grant of license - The amount paid by the appellant to NPL is not in the nature of royalty within the meaning of the DTAA between India - Admittedly NPL did not have a PE in India - there was no obligation on the part of the appellant to deduct tax at source u/s.195 - AT....