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    <title>2026 (7) TMI 212 - GUJARAT HIGH COURT</title>
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    <description>Commission payments to non-residents and travel agents were held, on the facts found, not to attract deduction under section 195 where the assessee had filed Form 15CB, submitted TDS returns, deducted tax wherever applicable, and otherwise complied with the Act and relevant DTAA requirements. Because the record did not show non-compliance in the tax audit report and the payments were not chargeable to tax under section 195, the payer could not be treated as an assessee in default under section 201. The Court also noted that no substantial question of law arose.</description>
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      <title>2026 (7) TMI 212 - GUJARAT HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=794326</link>
      <description>Commission payments to non-residents and travel agents were held, on the facts found, not to attract deduction under section 195 where the assessee had filed Form 15CB, submitted TDS returns, deducted tax wherever applicable, and otherwise complied with the Act and relevant DTAA requirements. Because the record did not show non-compliance in the tax audit report and the payments were not chargeable to tax under section 195, the payer could not be treated as an assessee in default under section 201. The Court also noted that no substantial question of law arose.</description>
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