tds on personal resi house design, Income Tax

[satbir singh wahi]

Amount of design charges are to be paid to Company in Singapore by a salaried individual , for design of residential house . Whether tds u/s 195 applicable ? As per Article 12 para 5 (d)  of DTAA with singapore this seems to be exempt .

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[CA GOPALJI AGRAWAL]

If the company has no PE in India and into the consultancy business, no withholding tax is required.