Dismissing the SLP of the Revenue the  wherein the High Court held that the U. S. Company did not have any permanent establishment in India. The assessee had made payments to the U. S. Company. The scope of the work was to generate customer leads using customer database, market research, analysis, and online research data and rightly held that the service provider had not made available any technical knowledge, experience, know-how, process, or development and transfer technical plan or technical design. The services were utilized in the U.S.A., and the payments made by the assessee were not taxable in India. Hence, Tax was not deductible at source on such payment.