fees paid in Netherlands for machinery installation in Madhya pradesh

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A company in India has paid fees to another company in Netherlands, for installing the machinery in madhya pradesh.
The Netherlands company has no office in India.
whether the payment made to Netherlands company is liable for TDS ?
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Section 9 (1) (VII) fees for technical services read with section 115A Tax applicable will be 10% (surcharge and Edu cess extra) or DTAA ( Please refer DTAA of Netherlands if lower rate is there), whichever is more beneficial to assessee.

Therefore as per sec 195 you will be liable to deduct tds.


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