Section 40(a)(i) Clarification: "Liable to Tax" Includes Right to Tax, Affecting TDS on Cross-Border Deals.

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....Disallowance u/s 40(a)(i) – TDS u/s 195 - Liable to tax in the contracting State cannot be implied as the person is actually liable to tax but would also cover the cases where the other contracting State had the right to tax such person - AT....