Tribunal held that  neither the Assessing Officer nor the Commissioner (Appeals) had examined the actual nature of services rendered by the agents so as to bring them in the ambit of the fee for technical services. If the payment made by the assessee was not chargeable to tax in the hands of the recipient it was not liable for tax deduction at source merely because of the Explanation to section 195 as it is a prerequisite contention for invoking provisions of section 195 that the payment is chargeable to tax in India in the hands of the recipient. (AY. 2015-16)