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    <title>2014 (2) TMI 902 - AUTHORITY FOR ADVANCE RULINGS</title>
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    <description>Line production services rendered outside India were treated as work covered by section 194C of the Income-tax Act, and were not characterised as fees for technical services, royalty, independent personal services, or other income. Because the recipient had no permanent establishment in India, the receipts were not chargeable to tax in India. As the underlying payment was not taxable in India, no obligation to deduct tax at source arose under section 195. The ruling followed the applicant&#039;s earlier similar case and was in favour of the assessee.</description>
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      <description>Line production services rendered outside India were treated as work covered by section 194C of the Income-tax Act, and were not characterised as fees for technical services, royalty, independent personal services, or other income. Because the recipient had no permanent establishment in India, the receipts were not chargeable to tax in India. As the underlying payment was not taxable in India, no obligation to deduct tax at source arose under section 195. The ruling followed the applicant&#039;s earlier similar case and was in favour of the assessee.</description>
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