TDS on Payments to Amazon Web Services Not Required u/s 195, Says Court, Citing Indo-US DTAA.

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....TDS u/s 195 - payment made towards web hosting charges to Amazon Web Services LLC (USA) - Indo-US DTAA - Even if the retrospective amendment is held to be applicable, the case of assessee of payment to Amazon being outside the scope of said Explanation 2(iva) to section 9(1)(vi) cannot make the assessee liable to deduct tax at source.....