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2025 (5) TMI 1970 - SCH - Income TaxTDS u/s 195 - assessee in default - payroll services rendered by IBM Philippines to the assessee - As decided by HC 2023 (2) TMI 174 - KARNATAKA HIGH COURT payments received by IBM Philippines shall not be liable for TDS u/s 195 of the IT Act. Therefore assessee cannot be deemed as an assessee in default HELD THAT - This application is at the instance of the Revenue bringing to our notice that inadvertently the Special Leave Petition came to be disposed of on the ground of low tax effect. However the matter needs to be heard on merits. We recall our order 2024 (9) TMI 1748 - SC ORDER by condoning the delay of 70 days in filing the application for restoration and restore the SLP to its original number on the file. In the meantime Revenue is directed to cure the defects as pointed in the Office Report dated 20-5-2025 immediately.
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