Sec. 40(a)(ia), 192 & 195 of Income-tax Act, 1961— TDS—Documents reveal that there was a contract between the assessee and the Kuwait based company and the license was granted by the Union Government to enable the assessee to provide services and assessee had employed the persons who had discharged the duties for Kuwait based company, therefore, assessee was in the process making payment of salary and therefore, there was no requirement of deducting tax at source under s. 195 — PR. CIT Vs. SUPRIYA SUHAS JOSHI - [2020] 313 CTR 482 (BOM)