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2018 (12) TMI 116 - AT - Income TaxTDS u/s 195 - payment of professional fees outside India - non deduction of tds - disallowance u/s 40(a)(ia) - income accrued in India - PE in India - Held that:- As decided in assessee's own case [2013 (11) TMI 188 - ITAT MUMBAI] none of these payments which were not liable or chargeable to be taxed in India, no TDS was required to be deducted under section 195, therefore, the findings given by the Commissioner (Appeals) is factually and legally correct and, accordingly, the same is hereby affirmed. Ground raised by the Revenue is, thus, dismissed.
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