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No TDS Required on Payments to Non-Residents if Income Isn't Taxable in India; No Need for Section 195 Order.

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....TDS on payment to non-residents - Once we come to the conclusion that the income embedded in these payments did not have any tax implications in India, no fault can be found in not deducting tax at source from these payments or, for that purpose, even not approaching the Assessing Officer for order u/s 195. - AT....