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In the result, the appeal of the assessee is partly allowed and that of the Revenue is dismissed
Bench: Shri Chandra Mohan Garg & Shri Girish Agrawal
87,983/- towards destination sampling charges to the parties of Hongkong and Singapore but Assessee has not deducted any TDS on the belief that the services are rendered outside India and India is having DTAA with China and Singapore, therefore, these charges are taxable in those countries. The AO did not agree in view of the Explanation