TMI BlogTDS u/s 195 - assessee in default - payroll services rendered by IBM Philippines to the assessee - as...TDS u/s 195 - assessee in default - payroll services rendered by IBM Philippines to the assessee - as per Article 7(1) of Indian Philippines DTAA, the business profits of an enterprise of a Contracting State shall be taxable only in that State unless the enterprise carries on business in the other Contracting State through a permanent establishment situated therein. Admittedly, there is no permanent establishment of IBM Philippines in India. - the payments received by IBM Philippines shall not b..... ..... X X X X Extracts X X X X X X X X Extracts X X X X
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