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    <title>1994 (8) TMI 27 - KARNATAKA High Court</title>
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    <description>An order transferring an assessee&#039;s case under section 127 has comprehensive effect and carries pending and future TDS matters with it, so the officer within the transferred jurisdiction may act on the TDS issue. Restriction under section 9 of the Foreign Exchange Regulation Act, 1973 does not by itself prevent accrual of liability where book entries create a definite liability, and later Reserve Bank permission does not nullify that accrued obligation. Section 195 of the Income-tax Act, 1961 applies to guarantee commission credited to a non-resident, so tax deduction at source is required on accrual or credit. The stated result is that TDS liability is triggered by credit or accrual in law, not by subsequent foreign exchange approval.</description>
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    <pubDate>Fri, 26 Aug 1994 00:00:00 +0530</pubDate>
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      <title>1994 (8) TMI 27 - KARNATAKA High Court</title>
      <link>https://www.taxtmi.com/caselaws?id=19643</link>
      <description>An order transferring an assessee&#039;s case under section 127 has comprehensive effect and carries pending and future TDS matters with it, so the officer within the transferred jurisdiction may act on the TDS issue. Restriction under section 9 of the Foreign Exchange Regulation Act, 1973 does not by itself prevent accrual of liability where book entries create a definite liability, and later Reserve Bank permission does not nullify that accrued obligation. Section 195 of the Income-tax Act, 1961 applies to guarantee commission credited to a non-resident, so tax deduction at source is required on accrual or credit. The stated result is that TDS liability is triggered by credit or accrual in law, not by subsequent foreign exchange approval.</description>
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      <pubDate>Fri, 26 Aug 1994 00:00:00 +0530</pubDate>
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