Political contribution deductions require assessee-specific proof before cash-back allegations can justify disallowance or unexplained-money additions...
TDS u/s 195 - Payment of royalty - disallowance u/s 40(a)(i) - What the appellant gets is only a copyrighted article to use the product for its internal business purpose and not any right in any copyright to exploit the same for commercial reasons so as to constitute the payment received in consideration thereof as royalty in terms of Article 13 of the India UK DTAA. - No TDS liability - AT
TDS u/s 195 - Payment of royalty - disallowance u/s 40(a)(i) - What the appellant gets is only a copyrighted article to use the product for its internal business purpose and not any right in any copyright to exploit the same for commercial reasons so as to constitute the payment received in consideration thereof as royalty in terms of Article 13 of the India UK DTAA. - No TDS liability - AT
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