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2018 (10) TMI 715 - AT - Income TaxTDS liability u/s 195 - Additions u/s 40(a)(ia) - payment made to overseas entity towards fees for technical services - Held that:- in the case of the assessee for the relevant assessment years 2010-11 & 2011-12 payment made towards commission to foreign agents for marketing, procurement of orders and systematic market research, provisions of Section 195 of the Act will not be applicable and consequently provisions of Section 40(a)(ia) of the Act cannot be invoked. - Decided in favor of assessee.
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