Navigating International Taxation Waters

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....cacies and implications of this case in the Indian context. Key Issues at Hand The primary issue in this case involved the assessment of tax liability under Section 195(2) of the Income Tax Act, 1961 for the Assessment Year 2018-19. The dispute arose from the order of the DCIT (Intl. Taxn.)-1 Ahmedabad, directing deduction of TDS @20% on a payment of USD 450,000 to Titan Shipping Limited, Marsha....

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....ng business of non-residents, was applicable. They cited Circular No. 723 by the Central Board of Direct Taxes, suggesting that Section 195 should not apply. They proposed that the TDS should be at 7.5%, aligning with the provisions of Section 172. Court's Findings and Conclusion The court scrutinized the submissions and relevant legal provisions. It was concluded that the payment was indeed....