Petitioner seeks to know whether it is required to deduct income-tax at source under section 192 on salary paid to such employees in India who qualify as non-residents in India. The application is admitted under section 245R(2).
BMW India (P.) Ltd., In re (2021) 436 ITR 287 / 279 Taxman 110/ 203 DTR 396/ 321 CTR 836 (AAR)
S. 245R : Advance rulings-Salaries paid to seconded employees in India whether qualify as non-resident-Credit for deduction of tax at source-DTAA-India-Japan. [Art. 15(1), S. 192]