What is TDS rate on Director remuneration payable to Non Resident director

The TDS rate on director remuneration paid to a non-resident independent director is 20% plus applicable surcharge and cess,as per Section 195 of the Income Tax Act, 1961.However , if the non-resident director has a Permanent Establishment in India, the tax rate would be determined based on the tax treaty between India and the country of residence of the non-resident director.

The payment of director remuneration to a non-resident independent director in foreign currency would be subject to the provisions of the ( F E M A),1999.

Sir, any other court judgement available on the director remuneration payable to non resident director ?