TMI BlogWithholding Tax (TDS) u/s 195 - payment of distribution fees - treatment as Royalty / FTS - DAPE...Withholding Tax (TDS) u/s 195 - payment of distribution fees - treatment as Royalty / FTS - DAPE [Dependent Agent Permanent Establishment - the Assessee cannot be treated as DAPE of GIL. Accordingly the distribution fees paid by the assessee to GIL is not liable for TDS u/s. 195 of the Act and therefore no disallowance u/s.40(a)(i) is warranted. - AT ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
