No tds deductible on payment for banner advertisement to Yahoo Inc. USA

Assessee company is a fully owned subsidiary of Yahoo. Inc. USA which is engaged in the business of providing consumer services such as search engine, content and information on wide spectrum of topics, e-mail, chat etc. During the course of assessment proceedings, it was noticed by the A.O. that the assessee has made a payment of Rs. 34,86,947/- to Yahoo Holdings (Hong Kong) Ltd. being cost of services/research material/advertisement media. Since the assessee company did not deduct tax at source from the payment remitted to Yahoo Holdings (Hong K

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