No TDS Required on Payments to University of Texas u/s 195, Article 12 of India-USA DTAA.

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....TDS u/s 195 - taxability of the receipts of University of Texas, USA - there was neither any patent/copyright used by the assessee against which the royalty was paid nor there was any technical know-how which was made available to the assessee. Thus in such facts and circumstances there is no liability on the assessee to deduct the TDS in pursuance to the Article 12 of India-USA DTAA. - AT....