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Income Tax - Highlights / Catch Notes

Home Highlights June 2019 Year 2019 This

TDS u/s 195 - referral fee paid to a foreign concern, in USA for ...

Case Laws     Income Tax

June 18, 2019

TDS u/s 195 - referral fee paid to a foreign concern, in USA for introducing clients - not in the nature of Managerial services,Technical services or Consultancy fees - payment entirely constituted its business profits in USA within the meaning of Article 7 of the India-USA DTAA and in the absence of any PE the said amount could not be brought to tax in India - No obligation to deduct TDS - no disallowance

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