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TDS u/s 195: Tax Withholding on Fees for Card Payment Services in India Linked to Singapore's PE.

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....TDS u/s 195 - PE in India - fees in respect of the services rendered for use of a global network and infrastructure to process card payment transactions for customers in India - DTAA with Singapore - The Applicant is required to withhold tax at source on amount attributed to the PE in India at the full applicable rate at which the non-resident is subjected to tax in India.....