Expatriate Employee Salaries: TDS Confirmed u/s 192, Not Section 195, with Proper Documentation Provided.

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....TDS u/s 192 or 195 - salary and other allowances of expatriate employees - As perused the TDS certificates, Forms 15CA and 15CB, tax deducted by the assessee and all these documents are part of the paper book. There is no dispute that the assessee has deducted tax at source u/s 192 of the Act. On the given facts of the case, we are of the considered opinion that the provisions of Section 195 of the Act do not apply. - AT....