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TDS u/s 195 Not Applicable When Indian Entity Operates Independently Without Forming a Permanent Establishment.

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....TDS u/s 195 - Existence of PE in India - When the entire relationship qua the distribution revenue is that of principal to principal basis and the Taj India is acting independently, then it moves out from the conditions laid down in Article 5(4) - It does not constitute PE in India - AT....