Company Not Required to Deduct TDS on Legal Fees u/s 195, No Technical Services Involved per India-US Treaty.

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....TDS u/s 195 - Non-deduction of TDS for legal and professional charges paid - no technical knowledge, skill, experience, knowhow or process is made available to assessee Company in terms of Article 12(b) of the India-US Treaty and Assessee has not defaulted in deducting TDS u/s 195 of the Act. Therefore the disallowance is unwarranted. - AT....