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    <title>Clarification Required - Timing of TRC, Form 10F, No PE Declaration and Form 15CA/15CB for TDS on Non-Resident Payments</title>
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    <description>Withholding tax on payment to a non-resident arises at the earlier of credit or payment under section 195. Where tax was correctly deducted, deposited, and reported at the time of credit using valid DTAA supporting documents, the withholding obligation for that income is generally treated as concluded, and subsequent remittance of the same amount does not ordinarily trigger fresh deduction merely because updated documents are not available. Tax Residency Certificate, Form 10F, and No Permanent Establishment declaration are relevant to establish DTAA benefit and the applicable withholding rate, and they are ordinarily expected to relate to the relevant financial year in which income is taxed and TDS is deducted.</description>
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      <description>Withholding tax on payment to a non-resident arises at the earlier of credit or payment under section 195. Where tax was correctly deducted, deposited, and reported at the time of credit using valid DTAA supporting documents, the withholding obligation for that income is generally treated as concluded, and subsequent remittance of the same amount does not ordinarily trigger fresh deduction merely because updated documents are not available. Tax Residency Certificate, Form 10F, and No Permanent Establishment declaration are relevant to establish DTAA benefit and the applicable withholding rate, and they are ordinarily expected to relate to the relevant financial year in which income is taxed and TDS is deducted.</description>
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