Payments to Facebook Ireland for ads not "royalty" u/s 195; no tax deduction needed, not in default.

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....TDS u/s 195 - royalty payments or not - Consideration for advertisement is paid to the overseas bank account of Non-resident - the payments made by the assessee the non-resident company M/s. Facebook, Ireland cannot be considered ad "royalty payments" - There is no requirement to deduct tax at source from those payments u/s. 195 - Hence the assessee herein cannot be considered as an assessee in default u/s. 201(1) of the Act. - AT....