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In view of the above discussion, the payment made to the non-residents at UK, USA, Germany and Spain cannot be disallowed. Accordingly, the order of the CIT(Appeals) in respect of payment made to the non-residents at USA and UK is set aside and the disallowance made by the Assessing Officer is deleted.

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Section 195 of the Income Tax Act, 1961 — TDS — Language translation was not a technical issue and even income from legal services rendered from abroad was not taxable in India without a permanent establishment in India. the copy of editing, indexing and proof reading required only knowledge of the language and did not require necessary expertise in the subject matter of text, thus, the services rendered by the non residents were not technical services and the payment received by the non residents from the assessee was not taxable in India — Deputy Commissioner of income tax vs. Integra Software Services P. Ltd. [2019] 76 ITR (trib) 491(Chennai) 

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