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Entities' Income Taxable Only in Home Country, Not India; Section 90(2) Treaty Provisions Prevail Over Income Tax Act.
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....Deduction of tax at Source (TDS) - any income derived by them is taxable only in their country of residence and not in India. Therefore, the Treaty provisions being more beneficial as per section 90(2) of the Act, will override the provisions of the Act. Therefore, there is no need for the assessee to deduct tax at source while reimbursing the salary expanses - AT....