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2004 (12) TMI 12 - AUTHORITY FOR ADVANCE RULINGS
Applicant had agreement with Timken-USA, pursuant to which the said company agreed to render various services in favour of applicant in USA – held that sum of US $ 756,728.26 cannot be said to represent recovery or reimbursement of the costs or expenses actually incurred by Timken-USA while rendering the services by it and that the entire amount is liable to be taxed in India and accordingly, the applicant is obliged to withhold income-tax at the appropriate rate whichever is less u/s 195(1)