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    <title>2024 (7) TMI 715 - ITAT DELHI</title>
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    <description>The ITAT Delhi ruled in favor of the assessee regarding TDS obligations under section 195 for payments to a non-resident entity. The assessee paid fees to Everest Global Inc. for software training services without deducting TDS. The tribunal held that since the non-resident had no permanent establishment in India, services were rendered outside India, and payments were made for earning income from sources outside India, the income was not taxable in India under section 9(1)(vii)(b). Therefore, no TDS deduction was required under section 195.</description>
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      <title>2024 (7) TMI 715 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=755495</link>
      <description>The ITAT Delhi ruled in favor of the assessee regarding TDS obligations under section 195 for payments to a non-resident entity. The assessee paid fees to Everest Global Inc. for software training services without deducting TDS. The tribunal held that since the non-resident had no permanent establishment in India, services were rendered outside India, and payments were made for earning income from sources outside India, the income was not taxable in India under section 9(1)(vii)(b). Therefore, no TDS deduction was required under section 195.</description>
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