Indian Tax Not Applicable on Nepal Shoot Payments to UK Models Due to DTAA; Section 40(a)(i) Not Triggered.

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....Payments were made to individual models for a shoot carried out in Nepal. The said payments were not chargeable to tax in India as per the DTAA between India and UK and there is no tax at source. Thus, the provisions of Section 40(a)(i) were not applicable - AT....