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    <title>2019 (10) TMI 1224 - ITAT INDORE</title>
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    <description>Payments for coal imports made to non-resident suppliers were not subject to withholding under section 195 because the Indian broker acted only as an independent intermediary, without authority to conclude contracts or exclusive control by the non-residents; no business connection or permanent establishment in India was established, so the assessee was not liable as an assessee in default under section 201. Inspection charges paid to a non-resident agency were also not fees for technical services, because the service was limited to inspection and certification and did not involve technical advice or skill; tax deduction was therefore not required and the TDS demand failed.</description>
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      <link>https://www.taxtmi.com/caselaws?id=387740</link>
      <description>Payments for coal imports made to non-resident suppliers were not subject to withholding under section 195 because the Indian broker acted only as an independent intermediary, without authority to conclude contracts or exclusive control by the non-residents; no business connection or permanent establishment in India was established, so the assessee was not liable as an assessee in default under section 201. Inspection charges paid to a non-resident agency were also not fees for technical services, because the service was limited to inspection and certification and did not involve technical advice or skill; tax deduction was therefore not required and the TDS demand failed.</description>
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      <pubDate>Wed, 21 Aug 2019 00:00:00 +0530</pubDate>
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