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TDS u/s 195 - remittance towards group cost recharge to its associated enterprise(AE) in Singapore - impugned services rendered for which the payment was collected by Singapore entity through cost recharge mechanism is not assessable as fee for technical services under Article 12 of India Singapore DTAA when it does not make available any technical knowledge skill experience etc. - no legal obligation to deduct withholding tax on the impugned remittance - Tri

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