Software Maintenance Charges Allowed: No Tax Deduction Required Under DTAA; Section 40(a)(i) Disallowance Not Applicable.

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....TDS u/s 195 - Disallowance u/s. 40(a)(i) in respect of payment of 'Software Maintenance charges' - Going by the beneficial provision in the DTAA vis-à-vis the Act, it is held that there was no requirement on the part of the assessee to deduct tax at source which should have called for any disallowance u/s.40(a)(i)....