Simulator Training Fees Not Classified as Royalty Under TDS Section 195; Payment Tied to Instructor-Led Training.

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....TDS u/s 195 - Royalty - The fact that the charges for use of the simulator is separately quantified on hourly basis does not mean that the Assessee is hiring the same or making payment for a right to use the same. Without the imparting of training by the instructors, the hiring of simulator on its own does not have any purpose. It cannot therefore be said that the Assessee paid royalty for use of simulator.....