https://www.taxtmi.com/highlights?id=69066 Withholding Tax (TDS) u/s 195 - payment of distribution fees - treatment as Royalty / FTS - DAPE [Dependent Agent Permanent Establishment - the Assessee cannot be treated as DAPE of GIL. Accordingly the distribution fees paid by the assessee to GIL is not liable for TDS u/s. 195 of the Act and therefore no disallowance u/s.40(a)(i) is warranted. - AT en-us Tue, 04 Apr 2023 16:58:25 +0530 Tue, 04 Apr 2023 16:58:25 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=69066 Withholding Tax (TDS) u/s 195 - payment of distribution fees - treatment as Royalty / FTS - DAPE [Dependent Agent Permanent Establishment - the Assessee cannot be treated as DAPE of GIL. Accordingly the distribution fees paid by the assessee to GIL is not liable for TDS u/s. 195 of the Act and therefore no disallowance u/s.40(a)(i) is warranted. - AT Highlights Income Tax Tue, 04 Apr 2023 16:58:25 +0530 https://www.taxtmi.com/highlights?id=69066