Assessee had taken an aircraft engine on lease rent basis from company  tax resident of Netherlands.  Assessing Officer held that rental payment made by assessee was taxable as royalty and was  liable to deduct TDS. Held that  since admittedly tax resident of Netherlands  did not have PE in India, said rental payment for aircraft engine paid to it was not chargeable to tax in India as per article 7 of DTAA between India-Netherlands. Not liable to deduct tax at source. (AY. 2017-18)