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No TDS u/s 195 for Embedded Software in Imported Nokia Phones, Says Court-Transaction for Complete Units.

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....TDS u/s 195 - non deduction of TDS on software embedded in mobile phones imported by the assessee during the previous year - Finished mobile phones were imported by the assessee from Nokia Corp for the purposes of sale against a lump-sum consideration and there was no separate payment made by the assessee towards the purchase of any software. - No TDS liability - AT....