The assessee paid consideration of certain amount towards advertisement services to an Irish company without deduction of tax at source. The AO  disallowed  payment  under section 40(a)(i) of the Act. On appeal   Commissioner (Appeals) held that   Irish-company had certified that it did not have Permanent Establishment (PE) in India and it was resident of Ireland for taxation purposes, hence, there was no liability upon assessee to deduct TDS under section 195 on such payment made for advertisement services.  On appeal order of CIT (A) is affirmed.  (AY. 2012-13)