No TDS on Payments to KPMG Switzerland Due to Mutuality Principle u/s 195; Indian-Swiss Tax Treaty Applied.

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....TDS u/s 195 - payment made to KPMG International, Switzerland without TDS - principle of Mutuality application - Indian-Switzerland tax treaty - Once such identity is established, the surplus income would not be exigible to the tax on the principle that no man can make a profit out of himself - No TDS liability - AT....