https://www.taxtmi.com/forum/issue?id=106830 Applicability of TDS under section 195 arises for payments to a foreign engineer consultancy for professional fees; withholding must follow domestic law and any applicable DTAA, considering payee residency, fee characterization, and PAN presence. The payer deducted tax at one rate but Form 27Q was rejected and the tax department indicated a higher withholding rate, prompting queries about departmental notifications, treaty relief, and procedural steps (withholding certificate, residency documentation, PAN) to rectify withholding and return compliance. en-us Sat, 24 May 2014 09:47:43 +0530 Thu, 23 Jan 2025 15:57:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/forum/issue?id=106830 Applicability of TDS under section 195 arises for payments to a foreign engineer consultancy for professional fees; withholding must follow domestic law and any applicable DTAA, considering payee residency, fee characterization, and PAN presence. The payer deducted tax at one rate but Form 27Q was rejected and the tax department indicated a higher withholding rate, prompting queries about departmental notifications, treaty relief, and procedural steps (withholding certificate, residency documentation, PAN) to rectify withholding and return compliance. Discussion-Forum Income Tax Sat, 24 May 2014 09:47:43 +0530 https://www.taxtmi.com/forum/issue?id=106830