Assessee, a licensed broker with IRDAI, made payment of reinsurance premium from an Indian insurance company to non-resident reinsurers (NRRs).Assessing Officer held that assessee had failed to deduct tax at source on said reinsurance premium paid to NRRs and held assessee as assessee in default as per provisions of section 201 of the Act. Held that since the assessee was merely a broker and did not have any ownership on premium amount transferred to NRR, there was no liability to deduct TDS for remitting said amount to these NRRs in Singapore. Further NRRs did not have PE in India, premium received by NRRs could not be held as chargeable to tax in India.  (AY. 2016-17)