Q. TDS on management executive program for 3 weeks in Japan u/s 195

Question

Dear Sir,

Whether TDS is deductible u/s 9(1)(vii) read with Section 195 on payments made by an Indian Company ( for its employees) to a Japanese institution conducting programs in Japan like Management executive programs, quality improvement programs for 2 to 3 weeks ??

Answer 1

These not being management services... in my view no TDS if that entity dies not have PE in India