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TDS) [(2010) 321 ITR 31 (Karn)] the Karnataka High Court held that the effect of the Supreme Court decision in Ishikawajima had not been obliterated. Insofar as how the explanation has to be construed, reliance has been placed on Sedco Forex International Drill Inc. v. CIT [(2015) 279 ITR 310 (SC)]. 5. Section 195 casts a liability on the person