Assessee had made payment of commission to non-resident agents who were operating outside India and submitted that no part of agents’ income arose in India as payments were remitted directly abroad. Held that since non-resident agents had rendered services in their respective countries and did not have either any business connection in India or any PE in India, commission paid to non-resident agents was not chargeable to tax in India at their hands and thus there was no necessity for assessee to withhold tax under section 195(1) on such payment. Held that the amounts paid by resident Indian end-users or distributors to non-resident computer software manufacturers or suppliers, as consideration for resale or use of computer software through end-user licence agreements or distribution agreements, was not royalty for use of copyright in computer software, and did not give rise to any income taxable in India, as a result of which persons referred to in section 195 were not liable to’ deduct any tax at source under section 195 (AY. 2014-15)