TDS on advertisment made to company of thailand

Dear Sudhir,

Before deciding on the rate of TDS, first we have to decide whether that income is taxable in India or not....

Amongst Others factors to be considered are -

1) Advertisment where it will be published in India or in Thailand,

2) DTAA with Thailand,

3) Whether that company is having any PE in India or not

So it's not that easy to comment...........