TMI Blog2019 (8) TMI 465X X X X Extracts X X X X X X X X Extracts X X X X ..... EXPORTS [ 2018 (5) TMI 1240 - GUJARAT HIGH COURT]. The ratio of the decision of this Court, which has been applied by the Tribunal is that a person paying interest or any other sum to a non-resident is not liable to deduct tax if such sum is not chargeable to tax under the Act. Having regard to the findings recorded by the tribunal relying on the decision of this Court referred to above, w ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nst the order passed by the Income Tax Appellate Tribunal, 'D' Branch, Ahmedabad, dated 19th September 2018 in the I.T.A. No.153/Ahd/2015 for the assessment year 2010-11. 2 The Revenue has proposed the following substantial question of law for the consideration of this Court: Whether the Appellate Tribunal has erred in law on facts in upholding ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... which has been applied by the Tribunal is that a person paying interest or any other sum to a nonresident is not liable to deduct tax if such sum is not chargeable to tax under the Act. Ultimately, the Tribunal held as under: The principles laid down in the above cited judgments are squarely applicable to the instant facts of the case. Thus, it can be safely concluded ..... X X X X Extracts X X X X X X X X Extracts X X X X
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