04 June 2012
As per Article 7 of Agreement for avoidance of double taxation of income with USA,The profits of an enterprise of a Contracting State shall be taxable only in that State unless the enterprise carries on business in the other Contracting State through a permanent establishment situated therein.
Accrodingly, It is not taxable in india and tds is not required to be dedcucted at source u/s 195
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