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Income Tax - Highlights / Catch Notes

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TDS u/s 195 - The agent may be main client, but the law mandates ...


TDS Section 195: Agent-Non-Resident Client Relationship Clarified; Non-Resident Must Be Primary Client for TDS Applicability.

May 11, 2020

Case Laws     Income Tax     AT

TDS u/s 195 - The agent may be main client, but the law mandates that the non-resident should be the main client of the agent. Therefore, this reasoning of the Ld. CIT(A) cannot be affirmed. The A.O. has also observed that 52% of the revenue of the agent is from non-resident. In our view, 52% of the revenue would not make the agent falling in the category of the working mainly for the non-resident.

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