Interest Payments to U.S. Supplier: No TDS Liability u/s 195, Section 194A Exemption for Banks Applies.

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....Disallowance u/s 40(a)(i) - TDS u/s 195 OR 194A - interest paid to its Banker for import of certain goods from a supplier in USA - Section 194A shall not apply in case, such income is credited or paid to any banking company - For invoking Section 40(a)(i) the burden squarely lies on the AO to establish in the first instance that the relevant TDS provisions were applicable - no TDS liability u/s 195....