Foreign Currency Ad Expenses Not Subject to Section 195 Withholding; No Disallowance u/s 40(a)(i) of Income Tax Act.

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....TDS u/s 195 - expenses in foreign currency - Advertisement and business promotion expenses - do not fall in the nature of technical, managerial or consultancy services - unless an amount (income) can be said to have accrued or arisen in India or deemed to have accrued or arisen in India, the provisions of section 195 is not applicable - no disallowance u/s 40(a)(i)....