section 195

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XYZ company is going to participate in exhibition in Dubai, we need to pay stall fee to them and exhibitors had been us TRC certificate. I need to know weather we need to deduct tds U/s 195?
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As per India-UAE tax treaty., exhibition service would fall under article 7 of the treaty ( being not falling under any specific article) and in the absence of any PE in India of Dubai entity. it's not chargeable to tax in India... collect a declaration certifying Dubai entity does not PE in India and TRC of entity to tk benefit

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