Held that there is nothing to show that the business support services rendered by ADP make available technology, skill, etc. to the assessee, the support services fee paid by the assessee-company to ADP is neither taxable under the provisions of s. 9(1) (vii) nor under the provisions of the India-Australia treaty and, therefore, the same cannot be disallowed under s. 40(a)(i) for non-deduction of TDS under s. 195; said payment cannot also be taxed in view of the application of the provisions of s. 90(2). Not liable to deduct tax at source. (AY. 2020-21)