Payments for Warranty & Rework Costs Disallowed u/s 195; No PE Means Home State Tax Only.

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....Disallowance of payment for preliminary warranty and reworking costs - TDS u/s 195 - it is categorical in so far as if the assessee in the contracting State does not have a PE in the other State, then the income of the assessee in the contracting State is liable to tax only in that contracting State and not in the other State. - AT....