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pymt to non resident

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Querist : Anonymous (Querist)
22 January 2011 amt is paid as technical fees to person in japan 1,00,000 jpy which is net of TDs.
as the person is not having PAN , the rate of TDS will be 20% ........am i supposed to calculate the TDS amt as Rs. 25,000 jpy (20%)or 25945 JPY (20.6%).......


which is right ?

22 January 2011 JPY 25945.00



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