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1981 (9) TMI 159 - ITAT CALCUTTA-BExtract: .......dent. Section 195 will be rendered otiose and unworkable. Since the section has to be interpreted in a manner that is workable, we have to hold that the provisions of section 195 with regard to the agents of non-residents would apply only to such persons who have actually been declared as agents by the ITO after issuing notice under section 163(2).
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