No TDS Liability on Payments to Non-Residents for Marketing Fees: Section 195 Not Applicable, Section 9(1)(i) Exemption Applies.

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....TDS u/s 195 - payment made to the non-residents - marketing consultancy fees - all the operations and activities of the non-residents were carried on outside India - The payment made to the non-residents is not taxable under section 9(1)(i) - No TDS liability - AT....