Saturday International Tax Gyan!! #taxmadeeasy #taxinpic
The withholding rate mentioned in DTAA is inclusive of cess and surcharge whereas we need to add cess and surcharge in withholding tax rate prescribed in Income Tax Act. [Deputy Commissioner of IT International Tax Circle 3(2)(1), Mumbai V. Marubeni Corporation, Japan [2022] 139 taxmann.com 458 (Mumbai – Trib.)]
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