Referral Fees Paid Abroad Not Subject to TDS u/s 195; No Services Rendered in India by Companies Involved.

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....TDS u/s 195 - nature of 'referral fee' paid outside India - No services were rendered in India by these two companies for facilitating the investment in the assessee company by these five companies. Merely reference of the 'consultancy charges' in the ledger of the assessee cannot be a ground to treat the charges paid by the assessee as consultancy charges - AT....