TDS for foreign company performing services in India

The finance team's 10% deduction does not align with current standard rates (it is either 20% plus cess under domestic law, or 15% under the US DTAA). However, under the India-USA DTAA, an AMC typically fails the "Make Available" clause and qualifies as business profits. If the US vendor provides a valid Tax Residency Certificate (TRC) and a formal "No Permanent Establishment (PE) in India" declaration, the income is completely exempt from tax in India, and the finance team should deduct 0% TDS.