India-UAE DTAA: No TDS Deduction Needed for Non-Resident Without Permanent Establishment in India u/s 195.

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....TDS u/s 195 - Disallowance u/s 40(a)(i) - the said income in the hands of non-resident has to be considered in the light of the provisions of DTAA between India and the Country of the nonresident, i.e UAE. In the absence of Permanent Establishment of the nonresident in India during the financial year relevant to impugned assessment year and any income attributable to such Permanent Establishment, such business income is not chargeable to tax in India. - When the amount paid by the assessee is not chargeable to tax in India then the assessee is not liable to deduct TDS u/s 195 - AT....