Sec. 195 of Income Tax act, 1961— TDS — Assessee and M/s DBPL could not be held to be Associated Enterprises in terms of Article-10 of the Treaty and assessee could not be treated as PE of M/s DBPL in India and further, the status of M/s EIFPL vis-à-vis M/s DBPL would be that of an independent agent and M/s EIFPL could not said to be PE of M/s DBPL, therefore, no profit could be said to have accrued to M/s DBPL in India as alleged by the revenue and s logical consequence, the assessee could not be treated as assessee-in-default in terms of Sec.201(1) & 201(1A) - NEXT GEN FILMS PRIVATE LTD. V/s ITO - [2020] 28 ITCD Online 049 (ITAT-MUMBAI)