TDS on Annual subscription fee -Foreign Company

This query is : Resolved 

18 January 2024 Dear Sir,

If an Indian company paid yearly subscription fee to a foreign company, for view latest fashion of leather products on his web portal through login id which is provide by foreign company and received subscription fee yearly for that id.

Foreign company have an Indian PAN registered with his London (UK) address and no PE in India.

TDS applicable or not if yes then which section.

Form 10F & TRC required or not.

21 January 2024 My view is that TDS not applicable here however we can wait for other experts for further views here.

https://incometaxindia.gov.in/booklets%20%20pamphlets/royalty-and-fees-for-technical-services.pdf
https://taxguru.in/income-tax/section-195-tds-non-resident-payments.html#google_vignette


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