TDS u/s 195 Not Applicable for License Fee Payments; Income Not Taxable in India.

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....TDS u/s 195 - payment towards license fees pursuant to the distribution agreement - in our considered view, the documents submitted before us clearly shows that the income of the payee is not taxable in India and assessee has already filed the relevant information u/s 201(1) of the Act which shows that the assessee cannot be regarded as ‘assessee in default’. - AT....