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U/S 195 under income tax act

This query is : Resolved 

A company is paying / reimbursing registration of patent & out of pocket
expenses of same to foreign company outside India.

1. Amount payable to foreign company is income arised in India for them ?

2. TDS U/s 195 is applicable to India company ?

Answer of both th epoints are "YES"

yes,income is liable to tds as per dtaa

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