Held that receipts of the non-resident assessee are not taxable in India under the provisions of s. 44BB for the reason that the assessee did not have a PE in India; impugned receipts partake the character of business income of the assessee hence, same are not taxable in India even under art. 7 of the Indo-Canada DTAA in the absence of a PE of the assessee in India. The  assessee being  non-Resident the  income is subject to TDS hence  interest cannot be levied.  (AY. 2012-13,  2019-20 to 2021-22)