Consultancy services and Independent personal services in the context of a DTAA explained

Advertisement Brief Facts of the Case and Question of law Brief Facts: the assessee Company made payment of Rs. 56,54,963/- to M/s. CGS International, UAE (“CGS International”) and Rs. 37,76,863/- to M/s. Marble Arts & Crafts LLC, UAE (Marble Arts & Crafts) (aggregating to Rs. 94,31,826/-). The AO noted that no TDS had been deducted by the assessee while making the payment to the said two foreign concerns. AO required the assessee to show cause why the said expenditure should not be disallowed under Section 40(a)(i) of the Act. The assessee did not deduct TDS on the sum of Rs. 9...