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Tax on Software License Import from Isreal

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(Querist)
03 January 2020 We have bought a Software License from an Israel Company and sold it to our customer in India. the software was directly downloaded by customer. The company in Israel does not have any office or permanent establishment in India. Israel company wants us to pay full invoice amount without any tax deductions as India and Israel has DTAA in place and the tax is getting deducted in Israel.

Let us know whether 10% TDS is applicable or not? If not then which code should we use for 15CA?

Thanks in Advance.

Regards,

Rama Mohan
9930132276
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CA R SEETHARAMAN

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CA R SEETHARAMAN (Expert)
03 January 2020 10% withholding tax under section 195 applicable.
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