No tax was deducted at source u/s 195 of the Act. Ld. A.O on observing that no tax has been deducted at source on the above stated payments for purchase of coal and inspection charges confronted the assessee vide show cause notice dated 27.6.2016 for why not treating the assessee in default u/s 201(1) and 201(1a) of the Act and seeking as to why not the non-resident sellers be subject to tax in India on the profits earned by them from the said transaction of exporting coal to India through agent namely SPEPL and also why the tax has not been deducted at source on the technical services i.e. inspection charges paid to the non-resident inspection agency.