TMI BlogTDS u/s 195 - withholding of tax - GBAs/BDAs are not paid for rendering any managerial, technical or...TDS u/s 195 - withholding of tax - GBAs/BDAs are not paid for rendering any managerial, technical or consultancy services but only for promoting sale on behalf of the assessee and therefore such payments are business income of the payees which squarely falls within the scope of the Article 7 of the respective DTAAs relating to ‘business profits’. It is an undisputed fact that the GBAs/ BDAs located overseas are non-residents and do not have PE in India. Hence, the payments to GBAs/ BDAs being th..... ..... X X X X Extracts X X X X X X X X Extracts X X X X
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