Consultancy Fees Not Disallowed: No Evidence of Indian Income or PE; TDS u/s 195 Not Required.

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....TDS u/s 195 - Disallowance u/s 40(a)(ia) on account of professional consultancy fees - AO has failed to point out in what manner the professional income has arisen or accrued in India or the said party had any PE or business connection in India or rendered any services in India - TDS u/s 195 does not arise - no disallowance....