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of ITAT examined TDS obligations u/s 195 for payments to foreign associates. Assessee contended payments qualified as professional services or business profits under respective DTAAs. AO had treated entire amount as fees for technical services without analyzing applicable DTAA provisions. ITAT directed AO to re-examine taxability considering specific DTAA provisions with respective countries, particularly clauses related to independent personal services including legal services. AO instructed to provide adequate hearing opportunity and allow submission of supporting documentation. Appeal allowed for statistical purposes, with matter remanded for fresh consideration of DTAA benefits.
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