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Non-Residents Targeted to Prevent Tax Avoidance; AO Not Required to Prove Before Applying Sections 92C, 92CA.

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....TP - although Chapter X has title 'Special provision relating to avoidance of tax' and aim of various sections under Chapter X is to check avoidance of taxes, diversion of income and funds by non-residents from India, it is not necessary that AO must demonstrate such avoidance and diversion of tax before invoking provisions of ss. 92C and 92CA... - AT....