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2010 (9) TMI 661 - AT - Income TaxDisallowance of expenditure - payments were made by the assessee for services rendered by the foreign non residents and disallowance has been made under section 40(a)(i)on the ground that no tax had been deducted at source - payments could not be disallowed in case of the assessee in view of the Article 26(3) of the Indo US Double Taxation Avoidable Agreement - provisions of section 40(a)(i) applicable for the relevant year no disallowance could be made respect of payments to the residents on the ground of non deduction of tax at source - no disallowance can be made in case of payments to the non residents also even if the amount is found taxable in India in their hands - claim of the assessee allowed
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