Distinction Between Search Fees and License Fees u/s 195: Search Fees Not Taxable as FTS in India Per DTAA Article 12(5)(a).

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....TDS u/s 195 - the search fee and license fee were distinct from each other and that the search fee received under the SA was independent of the LA and was not taxable in India as FTS under Article 12(5)(a)of the DTAA....