One of my client, a Pvt Ltd company, engaged availed a services of an Architects, from office in Dubai. These Architects have offices in UK and Dubai. Services are rendered at Dubai office.
India has signed a DTAA (double tax avoidance treaty) with UAE and the same is covered under Article 14 of the same.
Further the Architect does not have a fixed base for providing the services in India. Also his stay in India is less than 183 days.
Whether TDS is deductible or not against the payments made to Architects.
As per my opinion TDS should not be deducted. Pls guide.