Management Fees to UST Global Not Taxable u/s 195; No TDS Liability Due to DTAA Exemption.

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....TDS u/s 195 - Taxability of management fees paid by the appellant to UST Global - The remuneration received by the US Company for the services offered to the Indian Company being not a technical or consultancy service as defined under the DTAA, would also not be a fee for included services. - Not taxable - No TDS liability u/s 195.....