Tax Deduction at Source Required u/s 195 for Payments to Foreign Legal Counsel Not Covered by DTAA Benefits.

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....TDS u/s 195 - professional charges to counsel/ lawyers outside India - Norway, Denmark, Sri Lanka, Malaysia, Russia, Luxembourg, Australia, Republic of Korea, South Africa, New Zealand, Mexico, Indonesia, Colombia and Serbia - assessee should have deducted tax at source on the above payment u/s 195 as the recipient of the income are not entitled to avail benefit of article 14 or article 15 of the respective Double Taxation Avoidance Agreements. The disallowance made by the learned assessing officer cannot be found fault with. - AT....