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Non-resident order procurement payments exempt from TDS u/s 195; classified as business profits per DTAAs.

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....TDS u/s 195 - on payment made to two non-residents regarding order procurement services - DTAA between India and USA/Belgium - Both the non-resident derived their income as their business activity and their business profit is determined under Article 7 respective DTAA - none of the provisions of the Section 9 will be applicable and business income cannot be treated as fees for technical services - No TDS....

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