29 April 2023
Since the overseas entity does not have any Permanent Establishment (PE) in India, the amount paid towards subscription and membership fee outside India is not subject to TDS under section 195 of the Act.
02 May 2023
Sir, Section 195 applies whether or not a person has PE in India. For the removal of doubts, it is hereby clarified that the obligation to comply with sub-section (1) and to make deduction thereunder applies and shall be deemed to have always applied andextends and shall be deemed to have always extended to all persons, resident or non-resident, whether ornot the non-resident person has— ( i ) a residence or place of business or business connection in India; or ( ii ) any other presence in any manner whatsoever in India Can we interpret so
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