No TDS liability u/s 40(a) for fees to US agents; no technical services, no Indian business connection.

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....Disallowance u/s 40(a) - tds u/s 195 - fee for technical services - No information in the nature of technical, management or consultancy services had been provided by any of the agent. The assessee had no PE in USA. Both the agents are tax residents of USA and had no business connection in India nor they have any PE in India. None of the agents is related to any of the Director of the company directly or indirectly. All the payments have been made in US$ through proper banking channels. - No TDS liability - Additions deleted - AT....