S. 201 : Deduction at source-Failure to deduct or pay-Foreign remittance-Purchase of subscription-No liability to pay tax in India-Cannot be treated as assessee in default-DTAA-India-Singapore-SLP of Revenue is dismissed due to low tax effect. [S. 9(1)(vii), 201(1), 201(IA), 268A, Art. 5, 7, 12(3), 12(4)(a), 12(4)(b)]