S. 195 :Deduction at source – Non-resident – Income deemed to accrue or arise in India – Payments made for expert services of Non- Consultancy services – Managerial Service -Liable to deduct tax at source- DTAA-India Indonesia [ S.9(1)(vii)(b), 264 , Art, 12(3)(b), 14, 15 , Art , 226 ]