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Income Tax - Highlights / Catch Notes

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TDS u/s 195 - non-deduction of TDS on payment of export ...


No TDS Deduction Required on Export Commission to Italian Entity: No Business Connection in India u/s 195.

April 14, 2022

Case Laws     Income Tax     AT

TDS u/s 195 - non-deduction of TDS on payment of export commission to Foreign entity in Italy - whether there is a business connection or not, must be determined based on facts and circumstances of the particular case. In our opinion there is nothing on record which indicates that SPA is carrying out its business in India owing to which any portion of its income can be attributed to its Indian operations. - AT

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