Payments for Affiliation Not Classified as 'Royalty' u/s 195: No Tech Transfer Involved, Says IT Act & DTAA.

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....TDS u/s 195 - Since there is no transfer of technology or use of any technology and payment is only simply for affiliation, the above amount cannot be considered as ‘royalty’ either under the provisions of Income Tax Act or under the provisions of DTAA.....