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2008 (7) TMI 9 - AUTHORITY FOR ADVANCE RULINGS
Taxability of payment made to BTA (non-resident company) who provides lease circuit service to the resident company - Since BTA does not have any permanent establishment - the amount paid to BTA is not taxable and therefore no TDS is required to be deducted. Further the amount paid to BTA can not be treated as Royalty within the meaning of Article 12 of DTAA with Singapore.
