No TDS Required on Immovable Property Sales to Non-Residents Under DTAA Article 26 & Section 195.

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....In view of Article 26 of DTAA between USA and India, since no TDS is required to be made in case of sale of immovable properties within India, therefore, an assessee could not be burdened while making the payment to a non-resident for deducting tax at source u/s 195 - AT....