Mr. Bharat I am not agree with you at all , question remained unsolved the same by Mr. Deepak Tapse.
Mr. Deepak - Any Royalty Payment to non resident - by an Indian firm - Must be governed by section 195 and its provision .
''Section 195 is a self contained section and there are two different provisions for mitigation viz by the payer u/s 195 (2) and the payee u/s 195 (3)/section 197.
The payer can make an application to his respective Assessing Officer seeking permission to effect nil or lower deduction on a certain payment with cogent reasoning for the same in the application.''
The Route what Mr. Bharat has suggested kindly dont go by this , assesing officer at any point of time can deny the same.
Kindly dont put any rate in ETDS return please.