TDS Not Required on Quality Rebate Payments for Exports Per Section 195 and DTAA Article VII; No Disallowance Needed.

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....TDS u/s 195 - payment was made towards quality rebate on export - assessee has established that it is a quality rebate with relevant documents which goes to reduce the sale and as per Article VII of DTAA between India and UK, the business profits are taxable in contracting state as the recipient is foreign company having no PE - neither TDS required nor disallowance u/s 40(a)(i)....