S. 195 : Deduction at source-Non-resident-Foreign companies-Equalization levy-Direction to deduct tax at source 10 percent-When the assessee is subjected itself to Equalization Levy of 2 per cent on payments under consideration, as an interim measure, assessee would be entitled to receive its payment from GCI subject to a deduction of 8 per cent-DTAA. [S. 115JA, 166, 195(2), Art. 226]