ITAT rules appellant company not a Permanent Establishment of Japanese parent, no TDS liability u/ss 195 & 40(a)(i).

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....TDS u/s 195 - non-deduction of TDS u/s 40(a) (i) - assessee company is a subsidiary company of its parent company in Japan - the appellant is not the PE of Mitusi & Co. Ltd (Japan), hence in view of said findings of the Honorable ITAT there is no question of attribution of any profit of Mitusi & Co. Ltd (Japan) to the appellant company - No TDS liability - AT....