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TDS u/s 195 Applies to Use of Patents for Manufacturing in India; Includes Sales in USA. Withholding Tax Confirmed.

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....TDS u/s 195 - the patent/IPRs are utilized for manufacturing activities in India and the rest of the activity, i.e., sale in USA has to be viewed in conjunction with this activity and the same cannot be isolated - withholding tax liability confirmed - AT....

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