No TDS Required on Compensation for Breach of Contract with Foreign Buyer under DTAA Article VII and Section 195.

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Full Text of the Document

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....TDS u/s 195 - compensation paid for breach of contract for supply of material to foreign buyer - assessee’s failure to supply the export order which constitutes business transaction - There is no evidence brought on record that the sum paid to foreign buyer is income within the meaning of Article VII of DTAA to be taxable in India - neither TDS required nor disallowance u/s 40(a)(i)....