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2017 (8) TMI 840 - AT - Income TaxTDS u/s 195 - assessee treated as an A-I-D for not deducting tax with regard to payments made to RIRCL - P.E. in India - Held that:- The Ireland Co. did not have PE in India, that the assessee was under bonafide belief that it had not to deduct tax for the payment made to RIRCL. Therefore we hold that the assessee cannot be treated as A-I-D and that interest charged by the TDS officer u/s. 201(1A) has to be deleted. Confirming the order of the FAA, we decide effective Ground of appeal against the AO.
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