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2006 (11) TMI 139 - AAR - Income TaxApplicant itself is a resident in India has raised issue of tax liability of some of its non-resident employees lent to group companies abroad - salary paid by the applicant to Mr. Manish Gupta shall not be taxable in India, if the same has been offered for tax in the U. K. in pursuance of DTAA - applicant shall not deduct tax at source from salary paid to Mr. Gupta in India, provided it is satisfied from the details furnished u/s 191(2) that taxes have been paid on such payments in the U. K.
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