Professional Fees to Non-Resident Mahta Partners Not Considered Royalty; Demand u/ss 201 and 195 Quashed.

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....TDS u/s 195 - professional fees paid to Mahta Partners, LLC USA a non resident - in the nature of Royalty or not - DTAA - the assessee benefits from rich experience of the service provider is wholly irrelevant in the present context - further, it is not even the case of the authorities below that ‘make available’ clause is satisfied - demand raised uu/s 201 r.w.s. 195 stand quashed - AT....