TDS u/s 195 - payment was made towards quality rebate on export - assessee has established that it is a quality rebate with relevant documents which goes to reduce the sale and as per Article VII of DTAA between India and UK, the business profits are taxable in contracting state as the recipient is foreign company having no PE - neither TDS required nor disallowance u/s 40(a)(i)
TDS u/s 195 - payment was made towards quality rebate on export - assessee has established that it is a quality rebate with relevant documents which goes to reduce the sale and as per Article VII of DTAA between India and UK, the business profits are taxable in contracting state as the recipient is foreign company having no PE - neither TDS required nor disallowance u/s 40(a)(i)
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