TDS Not Applicable on Professional Services Payments u/s 195 Due to DTAA with Uganda, Article 14 Exclusion.

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....TDS u/s 195 - DTAA with Uganda - professional services - the services received by the assessee from these three persons is covered by article 14 and therefore, the same cannot be included in article 12 - article 12(3)(b) specifically provided that the term fees for technical services does not include payments for services mentioned in articles 14 and 15 of this convention - neither TDS was deductible nor disallowance u/s 40(a)(i)....