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of TDS u/s 195 - Disallowance of Project Specific Costs u/s 40(a)(i) - There cannot be a retrospective obligation to deduct tax at source and therefore as on the date when the assessee made payments to the non-resident for acquiring off-the-shelf software cannot be regarded as in the nature of royalty and therefore there was no obligation on the part of assessee to deduct tax at source. - AT
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