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    <title>2021 (7) TMI 1478 - KARNATAKA HIGH COURT</title>
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    <description>Disallowance under section 40(a)(i) for failure to deduct tax at source under section 195, and the treatment of salary reimbursements and other expenditure under Article 13 of the India-UK Treaty, are the central issues discussed. The text states that these questions had already been answered in favour of the assessee by an earlier judgment, so the substantive questions were treated as concluded against the revenue. The limitation objection was not decided and was left open.</description>
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      <description>Disallowance under section 40(a)(i) for failure to deduct tax at source under section 195, and the treatment of salary reimbursements and other expenditure under Article 13 of the India-UK Treaty, are the central issues discussed. The text states that these questions had already been answered in favour of the assessee by an earlier judgment, so the substantive questions were treated as concluded against the revenue. The limitation objection was not decided and was left open.</description>
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