S. 40(a)(i) : Amounts not deductible-Deduction at source-Non-resident-Payment of licence fee to holding company-Assessee submitted Certificate from Chartered Accountant and return and computation of income of payee which Showed that payee had disclosed payment in its return and paid taxes thereon-Held, as per Indo-Israel DTAA Income in question not chargeable to tax in India in hands of Non-Resident-No disallowance can be made-DTAA-India-Israel.[S. 201]