TDS on Non Residents. CA. Rajesh Patil

TDS on Non Residents. CA. Rajesh Patil Western India Regional Council 12 February 2011

Contents (1) Introduction Analysis of section 195 Payers covered Payees covered Payments covered Point of Tax Withholding Rate of Tax Withholding Grossing up 12 February 2011 TDS on Non-Residents 2

Contents (2) Application for lower TDS: By Payer By Payee Alternative Mechanism Remittance to Non-Residents Refund of Tax Withheld Consequences of non-compliance Withholding Mechanism Case Studies Case laws Key Considerations 12 February 2011 TDS on Non-Residents 3

Introduction. 17 February 2008 TDS on payments to Non-Residents 4

Introduction Objective and Need for TDS: Collection of Tax at source which protects revenue and avoids unnecessary hassles involving tax compliance to both IT authorities and non-residents (whose activities in India may be temporary or transient) TDS under the Act Chapter XVII Section 192, 194B, 194BB, 194E, 194EE, 194F, 194G, 195, 196A to 196D TDS on payments to Non-Residents 12 February 2011 TDS on Non-Residents 5

Analysis of S.195 of the Act S.195 S.195(1) S.195(2) S.195(3) S.195(4) S.195(5) S.195(6) Scope and Conditions for Applicability Application by payer for lower or nil withholding certificate Application by payee for lower or nil withholding certificate Validity period of the Certificate Power of the CBDT to issue notification Furnishing information in the manner prescribed 6

Introduction Section 195A Net of tax payments Does not represent final tax liability i.e. subject to assessment 12 February 2011 TDS on Non-Residents 7

Analysis of Section 195 (2) Scope different from other TDS provisions Applicable to any person making payment including Individuals/HUFs Any payments (excluding salaries) to Nonresidents are covered No threshold limit: TDS on any sum chargeable to tax Provision for Lower or Nil TDS CBDT s powers to issue notifications built in 12 February 2011 TDS on Non-Residents 8

Analysis of Section 195 Payers covered. 17 February 2008 TDS on payments to Non-Residents 9

Payers covered (1) Any person Including an Individual and HUF whether carrying on any business or not Agent also liable to deduct tax at source from payments to non-resident principal Amendment to S. 195(1) Authorised dealer who is responsible for remitting consideration for transfer of foreign exchange asset (not being short term capital asset) to the NRI or crediting it to his NR(E) account 12 February 2011 TDS on Non-Residents 10

Payers covered (2) Non-residents making payments to other nonresidents are also covered if payments are chargeable to tax in India : S.1 extends to the whole of India Theory of Extra Territorial Jurisdiction gets invoked Electronics Corp. of India 183 ITR 43 (SC) Malayalam Plantations Ltd. 53 ITR 140 (SC) CIT vs. M/s Eli Lilly & Co. (India) P. Ltd - 312 ITR 225(SC) No extra territorial jurisdiction Shrikumar Poddar 65 ITD 48 (Mum) Commentary of Kanga, Palkhivala and Vyas Page 2105 Triniti Corporation AAR 165 Taxman 272 STAR 99 ITD 91 (Mum) 12 February 2011 TDS on Non-Residents 11

Analysis of Section 195 Payees covered. 17 February 2008 TDS on payments to Non-Residents 12

Payees covered (1) Foreign Company Non company payees who are Non-Residents, including NRI Resident but not ordinarily resident (RNOR) covered? - Section 2(30) 12 February 2011 TDS on Non-Residents 13

Payees covered (2) Payment by Indian Branch to HO? Circular 740 dated 17 April 1996 Interest Circular 649 dated 31 March 1993 FTS ABN Amro Bank 280 ITR 117 (Kol-SB) Dresdner Bank 105 TTJ 149 (Mum) Payment to Indian branch of foreign company in India (eg. Branches of foreign banks) Circular 20 (II-4) dated 3 August 1961 Section 195(3) 12 February 2011 TDS on Non-Residents 14

Payees covered (3) Payment in India to agent of Nonresident Narsee Nagjee & Co v. CIT 35 ITR 134 (SC) Payment during the financial year Residential status? Residential Status Under the Income-tax Act vs. Treaty 12 February 2011 TDS on Non-Residents 15

Analysis of Section 195 Payments covered. 17 February 2008 TDS on payments to Non-Residents 16

Payments covered (1) Any sum chargeable to tax (other than salaries) Payments in kind Kanchanganga Seafoods Ltd - 265 ITR 644 Capital Gains if chargeable to tax 12 February 2011 TDS on Non-Residents 17

Payments covered (2) Gross sum vs. Income component Amount paid which wholly bears the character of Income The gross amount, the whole of which may or may not represent income or profits Superintending Engineer - 152 ITR 753 ( AP) Transmissions Corp. - 239 ITR 587 (SC) Cheminor Drugs Ltd - 76 ITD 37 (Hyd ITAT) Advisable to withhold taxes on gross sum if order not obtained from the Income tax authorities 12 February 2011 TDS on Non-Residents 18

Payments covered (3) Reimbursement vs. Income Raymond Ltd. - 86 ITD 791 (Mum ITAT) Maharashtra State Electricity Board - 90 ITD 793 (Mum ITAT) Clifford Chance 82 ITD 106 (Mum.) HNS India VSAT Inc. 96 TTJ 486 (Del.) Industrial Engineering Projects P. Ltd. 202 ITR 1014 (Del.) Danfoos Industries P. Ltd. 268 ITR 1 (AAR) Timken India Ltd. 273 ITR 67 (AAR) AT&S India P. Ltd. 287 ITR 421 (AAR) Cochin Refineries 222 ITR 354 (Ker) Advisable to withhold taxes on gross sum if order not obtained from the Income tax authorities 12 February 2011 TDS on Non-Residents 19

Payments covered (4) Nature of Income sum chargeable Act* Treaty Business or Profession S. 9(1)(i) A.5, A.7, A.14 Salary Income S. 9(1)(ii) A. 15 Dividend Income S. 9(1)(iv) and S 115A A. 10 Interest Income S. 9(1)(v) and S 115A A. 11 Royalties S. 9(1)(vi) and S 115A A. 12 FTS S. 9(1)(vii) and S 115A A. 12 Capital Gains S. 9(1)(i) and S. 45 A. 13 * Apart from section 5 wherever applicable 12 February 2011 TDS on Non-Residents 20

Point of Tax Withholding. 17 February 2008 TDS on payments to Non-Residents 21

Point of Tax Withholding Tax shall be withheld at the time of credit or payment whichever is earlier Interest payment by Government or Public Sector Bank or Public Financial Institution only on actual payment First Provisio to S. 195(1) Toshoku Ltd case ~ 125 ITR 525 ( SC ) Flakt ( India) Ltd case ~ 267 ITR 727 ( AAR ) Payment of Royalty under DTAA tax deductible on payment basis? OECD Commentary Uhde GMBH 54 TTJ 355 (Bom) National Organic 96 TTJ 765 (Bom) Flakt (India) Ltd 267 ITR 727 (AAR) Payment in Advance TDS at what time? 12 February 2011 TDS on Non-Residents 22

Rate of TDS. 17 February 2008 TDS on payments to Non-Residents 23

Rate of TDS Rates in force Rates of income-tax specified in the Finance Act or the rates specified in the DTAA, whichever is applicable by virtue of Section 90 or Section 90A S. 2(37A) - Circular No. 728 of 30 October 1995 Issue: Rates mentioned in sections 115A, 115AB etc OR rates mentioned in Finance Act/Treaty? Circular no. 740 dated 17 April 1996, rate beneficial to assessee to be applied Rates prescribed under DTAA to be increased by surcharge and Education Cess? DTAA uses term Income-tax Article 2: all taxes imposed on total income K. Srinivasan 83 ITR 346 (SC) Interest on tax refund whether debt incurred Lower rate under Treaty? P-17 of 1998 236 ITR 637 Castrol Ltd. (Mumbai ITAT) 12 February 2011 TDS on Non-Residents 24

Summary Section 195(1) Payment by Residents Payment by Non-residents Payment to Residents Not Applicable Indian Business or Source Deductible Payment to Non-residents Overseas Business or Source Deductible ~ Other than Royalties, FTS and Interest Payment for Indian Business or Source Payment to Residents and Non-residents Deductible?? Payment for Overseas Business or Source Payment to Residents and Non-residents Arguably not deductible ~ especially to non- residents 12 February 2011 TDS on Non-Residents 25

Grossing up of Tax. 17 February 2008 TDS on payments to Non-Residents 26

Grossing up of Tax Grossing up of tax Section 195A In case payment to non-resident is on net of tax basis in terms of agreement or arrangement E.g. Amt. payable to NR is 100 and TDS rate is 10%; Gross amt. for TDS purpose would be 111.11 (100*100/90) Not applicable in case of payments referred to in S 192(1A) - Non monetary perquisites taxable as salary Grossing up not to be done in case of presumptive tax CIT vs. ONGC 264 ITR 340 (Uttranchal) Exemption from grossing up u/s. 10(6A) ~ Royalties and FTS Exemption from grossing up u/s. 10(6B) ~ Other Income Exemption from grossing up u/s. 10(6BB) ~ Aircraft and aircraft engine lease rentals 12 February 2011 TDS on Non-Residents 27

Application for lower TDS. 17 February 2008 TDS on payments to Non-Residents 28

Application for lower TDS by Payer (1) Difference between S 195 (2) (Nil rate) and S 197 (Lower Rate) Applicability of respective sections Procedure for application no prescribed format Authorities having jurisdiction over the applicant Appeal against the order u/s. 195(2) Section 248, withholding and payment of tax is a prerequisite. Tax has to be borne by appellant Revision of 195 (2) order u/s. 263 BCCI s case ~ 96 ITD 263 ( Mum ITAT ) Whether mandatory to approach AO for non-withholding of tax? SOL Pharmaceuticals Ltd. 83 ITD 72 (Hyd) Maharashtra State Electricity Board 90 ITD 793 (Mum) Cheminor Drugs Ltd 76 ITD 37 (Hyd) STAR 99 ITD 91 (Mum) 12 February 2011 TDS on Non-Residents 29

Application for lower TDS by Payee (1) Difference between S 195 (3) and S 197 Applicability of S 195 (3) - Rule 29B(1) Fulfillment of conditions - Rule 29B(2) Appeal against the order u/s. 195(3) Covered u/s. 248?? Appeal can be filed suo moto - Without any order u/s. 195 Withholding and payment of tax is a must Tax has to be borne by appellant Appeal against the order u/s. 197 - Covered u/s. 246A?? Revision petition u/s. 264 permissible?? Application post credit or payment of amount shall not be entertained Circular No. 774 of 17 March 1999 In case of delay, one can apply to the CBDT for condonation of delay 12 February 2011 TDS on Non-Residents 30

Alternative Mechanism (1) Certificate of a Chartered Accountant certifying the tax withholding amount Circular by the RBI Circular No. 759 of 18 November 1997; Circular No. 767 of 22 May 1998 and Circular No. 10/2002 of 9 October 2002 Documents required Tax Residency Certificate issued by overseas tax authorities Copy of agreement with the non-resident, if any Copy of Invoice Letter from non-resident receiver Tax resident of the home country and eligible to tax treaty benefits It is the beneficial owner of the income It does not have any PE in India 12 February 2011 TDS on Non-Residents 31

Alternative Mechanism (2) Issues regarding Certificate by CA Understanding of the nature of payments Effect of Transfer Pricing Regulations Certificate of tax residence of Payee To examine PE issues Beneficial ownership Limitation of Benefit article in tax treaty 12 February 2011 TDS on Non-Residents 32

Remittance to Non-Residents New procedures effective from 1 July 2009 Sequence of events Obtain certificate in Form No. 15CB from a Chartered Accountant Furnish the information in Form No. 15CA, verified in the manner prescribed Form No. 15CA to be then electronically uploaded on designated website Take printouts of Form No. 15CA, sign and manually file with authorities Approach Bank for remittance 33

Remittance to Non-Residents (contd) Filing of Form No. 15CA and 15CB mandatory for all types of payments - No exemption for small, capital, non-business payments The payer has to report in Form No. 15CA on whether the payee is company, firm or other, a domestic company or not, principal place of business - These details may not be readily available In Form No. 15CA & 15CB, details of remitter bank to be given What will happen if payer decides to change the bank? The law has not prescribed any penalty for default in complying with the new provisions 34

Refund of Tax Withheld. 17 February 2008 TDS on payments to Non-Residents 35

Refund of Tax Withheld (1) Person making payment is entitled to claim refund in prescribed cases Circular No. 769 of 6 August 1998 & Circular No. 790 of 2 April 2000 replaced by Circular N0. 7/2007 of 23 October 2007 Refund can be granted to the payer with the approval of the Chief Commissioner or Director General Refund is first adjusted against any income-tax or wealth tax or any direct tax liability Interest u/s. 244A is not payable on such refunds 12 February 2011 TDS on Non-Residents 36

Refund of Tax Withheld (2) Undertaking to be given by the payer that TDS certificate has not been issued Non resident has not filed the return and time for filing has expired If certificate has been issued, the payer either should obtain it back or indemnified the Govt. Corresponding amount payable to non-resident is disallowed Claim should be made within 2 years from the end of the FY in which tax has been deducted Refund of TDS pursuant to favorable appellate order? TELCO 83 TTJ 458 (Mum) Samcor Glass Ltd. 94 ITD 202 (Del) 12 February 2011 TDS on Non-Residents 37

Refund of Tax Withheld (3) Situation Contract Cancelled Contract Cancelled Contract cancelled after partial execution Contract cancelled after partial execution Amendment in Law or notification under Act Order passed by Tax Authorities Double Deduction Others Criteria No remittance made to non resident Remittance made duly refunded by non resident No remittance made for non-executed portion of contract Remittance made duly refunded by non resident or no remittance made for non-executed portion of contract but tax deducted Remitted amount becomes exempt Tax deduction liability of tax deductor gets reduced Same amount deducted twice by mistake Grossing up not required or Tax paid at higher rate without considering lower rate under tax treaty 12 February 2011 TDS on Non-Residents 38

Consequences of Non-Compliance. 17 February 2008 TDS on payments to Non-Residents 39

Consequences of Non Compliance (1) Disallowance of payments to non-residents u/s. 40(a)(i) Tax deductible but not deducted or after deduction not paid before the due dates Allowable in the year of payment Disallowance of salary payments to a person outside India or a non-resident u/s. 40(a)(iii) Tax is not paid thereon nor deducted therefrom 12 February 2011 TDS on Non-Residents 40

Consequences of Non Compliance (3) Levy of interest u/s. 201(1A) Recipient has paid full tax on such payment Citi Bank N.A. case ~ 179 CTR 121 ( Mum) Hindustan Coca Cola Beverages Private Limited 293 ITR 226 [SC] Levy of penalty U/s. 221 ~ Failure to pay tax U/s. 271C ~ Failure to deduct tax Invoking of prosecution u/s. 276B Madhumilan Syntex Ltd 290 ITR 199 (SC) 12 February 2011 TDS on Non-Residents 41

Withholding Mechanism. 17 February 2008 TDS on payments to Non-Residents 42

Withholding Mechanism (1) NO Payment Taxable Under ITA YES Whether DTAA Applies to Non-resident YES Whether NR has a PE in India NO YES No TDS NO Whether payment covered under Specific article? Whether effectively connected to PE? YES NO YES Deduct Tax Deduct TDS ~ Specific article Deduct TDS ~ Business Income Remittance of Payments 12 February 2011 TDS on Non-Residents 43

Withholding Mechanism - Issues Whether the receiver is a Resident of a Contracting State Meaning under respective tax treaty Legal Liability Vs. Fiscal Liability Azadi Bachao Andolan s case ~ 263 ITR 706 (SC) Whether payment is covered under specific article of treaty? Specific exclusions from taxability of income Explanation to S 9(1)(i) Article 5(3) ~ Preparatory and auxiliary activities Difference between Business Connection and PE Business connection is a wider concept than PE Taxability to the extent of income attributable to activities carried out in India Section 9(1)(i) and Rule 10 Article 7(2) of the DTAA 12 February 2011 TDS on Non-Residents 44

Case Studies. 17 February 2008 TDS on payments to Non-Residents 45

Case Study 1 POINT OF TAX WITHHOLDING Facts Company A Ltd entered into agreement for provision of know-how with S Inc Agreement subject to approval of the Government Royalty payable on annual basis and payments accrued in the accounts for the FY 2006-07 Approval granted by the Government in the next FY 2007-08 Issue Whether tax need to be deducted in the FY 2006-07? Whether expenditure deductible in the FY 2006-07? 12 February 2011 TDS on Non-Residents 46

Case Study 2 TAX WITHHOLDING UNDER VOID AGREEMENTS Facts S Inc provided technology to its subsidiary A Ltd. for payment of annual royalty A Ltd. applied to the Government for approval of the agreement for payment of royalty Royalty amount was credited in the accounts for the FY 2006-07 Government rejected the approval and rejection letter was issued in the next FY 2007-08 Royalty amount was reversed in the FY 2007-08 Issue Whether tax need to be deducted in the FY 2006-07? 12 February 2011 TDS on Non-Residents 47

Case Study 3 TDS ON ADJUSTMENTS Facts X Ltd. entered into agreement for with A Gmbh for marketing of products in Germany A Gmbh entitled to commission on sales in Germany and required to remit sales consideration after adjusting its commission X Ltd. receives net sales consideration from A Gmbh Issue Whether X Ltd. is required to withhold tax from commission to A Gmbh? 12 February 2011 TDS on Non-Residents 48

Case Study 4 TDS BY NON - RESIDENTS Facts A Inc sells shares of S Mauritius Ltd. to another non resident B Pte S Mauritius in turn holds entire share capital of X Ltd. B Pte makes payment of sale price to A Inc in the Singapore bank account Entire management and control of X Ltd. is entirely in Mauritius Issue Whether B Pte is required to withhold tax from payment of sale consideration to A Inc? 12 February 2011 TDS on Non-Residents 49

Case Study 5 TAX RECOVERY FROM PAYER Facts A Inc has availed services of M Ltd. The services are in the nature of technical services A Inc makes payment of fees to M Ltd. without deduction of tax at source M Ltd. has paid appropriate income-tax on its income in India Indian tax authorities have issued notice to A Inc for payment of TDS along with interest and initiated penalty proceedings Issue Whether Indian tax authorities are entitled to recover TDS amount from A Inc? Whether penalty cam be levied on A Inc? What could be other tax implications for A Inc? 12 February 2011 TDS on Non-Residents 50

Case Study 6 REIMBURSEMENT OF EXPENSES 1. A Inc incurs travel expenses on behalf of X Ltd. X Ltd wishes to reimburse such payments to A Inc. 2. A Inc makes payment for use of know-how on behalf of M Ltd. M Ltd wishes to reimburse such payments to A Inc. 3. A Inc provides services of its technicians to M Ltd. and charges only cost to M Ltd. M Ltd wishes to reimburse such payments to A Inc. 4. A Inc acts as a global co-ordination center for the group and provides various support services to its group companies. A Inc has charges proportionate cost to M Ltd. for such services.m Ltd wishes to make payment to A Inc. for the services 12 February 2011 TDS on Non-Residents 51

Agency Commission payable to foreign agents (1) CBDT vide Circular No. 7 dated 22 October 2009 has withdrawn the Circular No. 23 dated 23 July 969 ( Circular 23/1969) which clarified if a non-resident has a business connection in India, it is only that portion of the profit which can reasonably be attributed to the operations of the business carried out in India, which is liable to income-tax Issue Whether agency commission payable to the foreign agents of Indian exporters is liable for withholding tax? 52

Agency Commission payable to foreign agents (2) Circular No. 23/1969 and the subsequent Circular 786/2000 were merely clarified the position under section 9 of the Act. The payment to non-resident agent does not accrue or arise in India if - The non-resident agent operates outside India - The payment is direct remitted abroad - The transaction is on principal to principal basis Since, provisions of section 5(2) and section 9 are unchanged the withdrawal of Circular 23/1969 will not impact the principles laid down by the judicial precedents till date If the foreign collaborator has not rendered any services in India, no income deemed to be accrued or arise in India 53

Case Laws. 17 February 2008 TDS on payments to Non-Residents 54

Consequences of failure or pay TDS (1) Case Law CIT vs Samsung Electronics Ltd[185 Taxman 313(2009)(Kar)] Held that an application is necessary u/s 195(2) even when the sum is not so chargeable to tax and when it is not so made then the deduction u/s 195(1) is mandatory. In the view of the aforesaid judgement, when the payer has not deducted tax at source, then the payment would be disallowed u/s 40(a)(i), without even coming to the conclusion that the payment is chargeable to tax in the hands of the recipient. This may lead to an interesting case, say, where the payer neither made an application u/s 195(2) nor deducted tax at source u/s 195 and hence the amount was disallowed in his hands u/s 40(a)(i). 55

Consequences of failure or pay TDS (2) CIT vs Samsung Electronics Ltd[185 Taxman 313(2009)(Kar.)] Issues What happens when Form 15CA and 15 CB is provided? CBDT Circular No.759 dated November 18, 1997 prescribes an undertaking in the nature of indemnity from the assessee (now Form 15CA) and auditor s certificate (now Form 15CB) before a remittance could be made This development substituting the procedure under Sec. 195(2) and (3) in the light of rule-making power under Sec. 195(5) was not brought to the notice by the Hon ble Karnataka High Court. Auditors can, therefore, continue to give such certificate, where no tax is required to be deducted to enable remittance without any further formality 56

Consequences of failure or pay TDS (3) CIT vs Van Oord ACZ India vs. CIT [ (Del)] Facts The assessee reimbursed mobilization and demobilization expenses to its subsidiary in Netherlands. The assessee filed an application for obtaining NIL withholding tax certificate and the Assessing Officer rejected the application and directed to deduct tax at 11%. However, the assessee did not deduct tax on the entire amount The sum was not held to be taxable in the assessment of the payee Whether assessee responsible to deduct tax and treated as assessee in default if the sum is not chargeable to tax? 57

Consequences of failure or pay TDS (4) CIT vs Van Oord ACZ India vs. CIT [ (Del)] Held Delhi High Court has upheld that the obligation to deduct the tax at source u/s 195 (1) arises only when the payment is chargeable to tax. The High Court analysed the judgment of Supreme Court in case of Transmission Corporation (1999) (239 ITR 587) (SC) and observed that the apex court was not confronted with the situation where the amount paid was not chargeable to tax in the hands of nonresidents at all. The Karnataka High Court decision in the case of Samsung Electronic Company Ltd distinguished as in case of Samsung the payer in its own assessment wanted to show that the amount paid by it to the payee is not chargeable to tax in the hands of payee. 58

Consequences of failure or pay TDS (5) Issues CIT vs Van Oord ACZ India vs. CIT [(Del)] The decision has linked the withholding tax obligation of the payer with the final assessment of the payee The withholding tax obligation needs to be examined at the time of making payment whereas completion of the final assessment of the payee will happen later which can go up to six years 59

Consequences of failure or pay TDS (6) Prasad Production Limited (ITA No. 663/Mds/2003) (TMad) (SB) The Chennai Special Bench reiterated that the person making payment to the non-resident would be liable to deduct tax if the payment so made is chargeable to tax under the Act If the payer is under bonafide belief that no part of the payment has income character, section 195(1) will not apply and therefore it is not necessary to apply the Assessing Officer under section 195(2) of the Act The Tribunal interpreted the Circulars of the CBDT setting out the alternative procedure for TDS The Supreme Court decisions in case of Transmission Corporation and Eli Lilly & Co have been followed 60

Consequences of failure or pay TDS (7) Held: GE India Technology Centre Pvt. Ltd 327 ITR 456 (SC) Section 195 has to be read in conformity with section 4,5 and 9. Sums chargeable under the provisions of the Act would refer to such amounts, which should have an element of income in them as required under the provisions of the Act, and the treaty provisions, and hence would be liable to tax under the Act. Section 195 contemplates not merely pure income payments, but also covers composite payments which has an element of income embedded or incorporated in them Section 195 will apply only if payments chargeable to tax 61

Consequences of failure or pay TDS (8) Held: GE India Technology Centre Pvt. Ltd, (contd..) Transmission Corporation applicable only if payer has a doubt as to amount on which tax is to be deducted. If a payer is certain on the income portion on which tax should be deducted, he can make his own determination If a payer has doubt on the income portion embedded in amount payable, he can apply to Assessing Officer. Since AO had not decided the issue on merits the matter remanded back to AO. 62

Key Considerations. 17 February 2008 TDS on payments to Non-Residents 63

Key Considerations Critical in view of increasing Cross Border Transactions Payment to non-residents should be thoroughly examined from tax withholding perspective Under the beneficial provisions of the ITA or DTAA Payments can be remitted under the alternate mechanism (with CA Certificate) if the case is strongly supported by judicial precedents. Certificate should provide detailed reasoning supported by the opinion of the CA In case of doubt coupled with substantial amount, advisable to obtain tax withholding order under S 195 Mitigate against severe consequences of non- compliance with S 195 12 February 2011 TDS on Non-Residents 64

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