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      <description>Internet private line charges paid to a non-resident service provider were treated as not taxable as royalty on the payment dates, because the expanded definition of royalty in section 9(1)(vi) had not yet come into force. Tax deduction at source under section 195 could not be assessed by reference to a later retrospective amendment, and the principle that a person cannot be required to do the impossible applied. On that basis, disallowance under section 40(a)(ia) was held unsustainable and the addition was directed to be deleted in favour of the assessee.</description>
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