Non-Resident Financial Services Not Taxable in India u/s 195; Services Neither Rendered Nor Utilized Locally.

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....TDS u/s 195 - financial services - services were neither rendered in India nor utilized in India - explanation to Section 9(1)- though widened the scope of applicability of Section 9 but The question of non-resident having rendered services in India is quite different from such services having been consumed by the assessee in India - held not taxable in India....