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Court Rules Professional Fees to Non-Resident Non-Taxable in India u/s 40(a)(ia) and U.K. DTAA.

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....TDS u/s 195 - Disallowance u/s.40(a)(ia) - non deduction of TDS on professional fee - U.K. DTAA - There is no iota of evidence on record to which it can be assumed that Mr. Arnold Allen was having fixed place in India - this payment is not liable to be taxed in India - AT....