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2005 (8) TMI 33 - AUTHORITY FOR ADVANCE RULINGSMRSC, a non-resident company had entered into a Solution Provider Agreement (SPA) with HBSPL (applicant, an Indian company) for supplying packaged business software solutions – held that, in view of the provisions of section 195(1) there exists a legal obligation on the part of HBSPL to withhold taxes while making payment for the software purchased from MRSC
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