TDS Required on Royalty Payments to Foreign Carriers Despite Favorable Ruling on Foreign Technical Services Aspect.

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....TDS liability on UC/bandwidth Charges paid to foreign carriers - When on one aspect, the matter is decided against the assessee i.e. Royalty aspect in the present case, it cannot be held that no TDS is required to be deducted even if on some other aspect i.e. on FTS aspect in the present case, it is held that TDS is not required to be deducted on that aspect.....