Foreign Referral Fee Not Taxable in India Under Article 7 DTAA; No TDS Deduction Required per Section 195.

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....TDS u/s 195 - referral fee paid to a foreign concern, in USA for introducing clients - not in the nature of Managerial services,Technical services or Consultancy fees - payment entirely constituted its business profits in USA within the meaning of Article 7 of the India-USA DTAA and in the absence of any PE the said amount could not be brought to tax in India - No obligation to deduct TDS - no disallowance....