S. 195 TDS deductible on property purchase payment to GPA of NRI

Shri Bhagwandas Nagla Vs ITO (International Taxation) (ITAT Hyderabad) Conclusion: TDS under section 195 was to be deducted in case payment for purchase of immovable property made to GPA (general power of attorney) holder of non-residents because, at best, GPA holder could be considered as only a conduit between assessee and the owners of property and therefore, in true sense, assessee had made payment to non-residents only. Held: Assessee, being a resident, had purchased an immovable property from the NRIs and the sale deed had been executed by the GPA holder of the non-residents. Assessee’...