https://www.taxtmi.com/caselaws?id=35666 An assessee already liable to be assessed as agent of a non-resident under section 163 could not be subjected again to tax-deduction-at-source liability under section 195(1) or treated as an assessee in default under section 201 for the same payments. The statutory scheme was read to prevent the revenue from recovering the same tax in two different forms, and section 161(2) was treated as a complete answer to the attempt to impose duplicative consequences. On the facts, where the assessee's position as agent remained the same throughout the relevant years, the court held that the TDS default provisions did not apply. The question was answered in the negative, in favour of the assessee. en-us Mon, 31 Aug 1981 00:00:00 +0530 Mon, 15 Mar 2010 18:44:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=35666 An assessee already liable to be assessed as agent of a non-resident under section 163 could not be subjected again to tax-deduction-at-source liability under section 195(1) or treated as an assessee in default under section 201 for the same payments. The statutory scheme was read to prevent the revenue from recovering the same tax in two different forms, and section 161(2) was treated as a complete answer to the attempt to impose duplicative consequences. On the facts, where the assessee's position as agent remained the same throughout the relevant years, the court held that the TDS default provisions did not apply. The question was answered in the negative, in favour of the assessee. Case-Laws Income Tax Mon, 31 Aug 1981 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=35666