IF a Payment is made to a comany based in USA for availing server on rent and subsequently such server is made availbale to the clients in india by the assessee, than wheter such payment for server is liable to tds, considering the fact that such company is located in USA and it does not have any branch or permanet establishment in India. Do we have to consider provision contained in DTAA with USA for such payments? Moreover if the Tds is dedutible, will it be deductible u/s 194H or 194J. Kindly clarify on above issue.
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