Withholding Taxes
What is withholding tax?
Government of Nepak has written law (Income Tax Act, 2058) that require taxes to be paid before the money can be spent by the payer on the payee’s behalf. This ensures the taxes will be paid first and will be paid on time, rather than risk the possibility that the final tax-payer might default at the time when tax falls due in arrears.
Tax withholding, also known as tax retention, Pay-as-You-Go, Pay-as-You-Earn, or a Prélèvement à la source, is income tax paid to the government by the payer of the income rather than by the recipient of the income. The tax is thus withheld or deducted from the income due to the recipient. In most jurisdictions, tax withholding applies only on employment income. Many jurisdictions also require withholding taxes on payments of service fee, interest, dividends, royalties, rent or even the sale of real estate.
Typically the withheld tax is treated as a payment on account of the recipient’s final tax liability, when the withholding is made in advance. It may be refunded if it is determined, when a tax return is filed, that the recipient’s tax liability is less than the tax withheld, or additional tax may be due if it is determined that the recipient’s tax liability is more than the tax withheld.
Why is withholding tax?
Governments use tax withholding as a means to combat tax evasion, and sometimes impose additional tax withholding requirements if the recipient has been delinquent in filing tax returns, or in industries where tax evasion is perceived to be common. In some cases, the withheld tax is treated as discharging the recipient’s tax liability, and no tax return or additional tax is required. Such withholding is known as final withholding.
Withholding Taxes Under Section 87
Here we will discuss on various types of payments envisaged by Income Tax Act, 2058 and how withholding applies on such payments. Please explore the meaning of income sourced in Nepal in my other blog here: Income Sourced In Nepal: Definitive Analysis
Nepal sourced remuneration payment under Section 87(1) by resident employer to employee
Legal Provision and Applicable Withholding Rate
Section 87(1): When making payment which has source in Nepal and is to be included in computing the income derived by any employee or worker, each resident employer shall deduct (withhold) tax at the rate referred to in Schedule-I.
Section 87(2): The liability of an employer required to withhold tax pursuant to sub-section (1) shall not decrease or end by virtue of the following:
(a) If the employer has the right or duty to deduct or hold up or subtract any other amount from the said payment, or
(b) If the income earned by the employee or worker from employment cannot be subtracted pursuant to other laws in force.
Rule 31: Any employer shall withheld tax from a payment to an employee under section 87(1) in the following method:
a) The employer may take into account any reduction available in calculating the employee’s tax payable under section 51 of the Act;
b) The employer shall withheld tax on monthly proportion of calculated annual tax liability from payments to be made to the employee for an income-year.
When is it a final withholding payment?
Section 4(3): Notwithstanding Section 4(2), the income tax payable by a resident individual under Section 3(a), who meets all of the following conditions, is equal to the sum of the amounts to be withheld under Section 87 by the employer from payments to be made to the individual during the year:
a) The income for the income year includes only the income from the employment having source in Nepal, and
b) All of the employers are resident and has only one employer at a time during the year, and
c) Who only, claims a credit with respect to medical costs paid by the employer, a reduction in taxable income with respect to retirement contributions paid by the employer, and does not claim a reduction in taxable income with respect to donations or gifts under Section 12.
Section 92(1)(Cha): Taxable payments made to non resident person under section 87, section 88, section 88Ka or section 89 are final withholding payments.
General Exceptions to Section 87
Section 87 applies on Nepal sourced remuneration payment being made by resident employer. There aren’t any exceptions to this. Under Section 67(6)(i) of ITA, remuneration payment is sourced in Nepal where the payment is:
• payment for employment rendered or forbearance from rendering employment in Nepal, regardless of place of payment
• payment made by GON for employment rendered or forbearance from rendering employment, regardless of place of payment
Red Flags to Section 87
1🚩. Even non business payments by an individual employer are not exempt from withholding on the remuneration payment being made under Section 87.
2🚩. Unlike in Section 88, it is not explicitly stated in Section 87 that exempted income are not subject to withholding. However, it is ony fair to assume that exemption from taxation means exemption from application of withholding taxes as well. Even if one were to dispute this, such exempt income would not be subject to withholding taxation in the first palce as they are excluded from calculating employment income in the first place, under Section 8(3) of the Act.
3🚩. Payments like retirement payment under Section 2(gNa) are employment income too. They fall under the purview of Section 8 which includes employment income. However, specific withholding provision exists under Section 88(1), Section 88(1)(1) and Section 88(2)(Ga) for retirement payments. Further, Section 92(1)(Chha) and Section 92(1)(Gha) of the Act also states that retirement payment made by GON/ARF/UARF, all other retirement payment (except for regular pension received under pension scheme) and payment of gain from interest in UARF by resident person are subject to final withholding taxation. Where final withholding taxes are applicable in such remuneration payments, such amounts are excluded from calculating an individual’s income from employment under Section 8(3) of ITA.
4🚩. Is Section 87 intended to be applicable in all forms of employment rendered in Nepal even when the remuneration payment is made for non-business purposes by an individual? Generally, non business payments by an individual are not required to withhold taxes, but this exception is not available in regard to the remuneration payment. How has Income Tax Act, 2058 defined the term “employment”. Income Tax Act has not provided any specific defintion of employment as such. “Employment” is the dominant definition and whether an employment exists is primarily determined according to general law. Employment is typically an earning activity consisting predominantly of the provision of labour by an individual. Labor Act, 2074 of Nepal has put the meaning of employment in extended manner, in particular, to include most “managers” of entities, e.g. directors of a company and trustees of a trust. However, a limiting threshold (by number of employees or ratio of employee expense) as to what constitutes an employment is not provided in the Labor Act, unlike in previous Labor Act, 2048; where a minimum number of 10 employees were required to constiture an employment engagement. This becomes particularly relevant where an individual employees staffs for household or individual reasons. Should that amount to an employment or should the employer’s activity constitute an “enterprise” for it to be categorized as an employment activity? This is a common question and I view that without any entrepreneurial role of the employer, such individual engagement should not be viewed as employment and application of withholding taxes and (technical) compliance requirement of labor and social security laws should not extend as such. This is however, debatable.
Withholding Taxes under Section 88
Here we will discuss on various types of payments envisaged by Income Tax Act, 2058 and how withholding applies on such payments. Please explore the meaning of income sourced in Nepal in my other blog here: Income Sourced In Nepal: Definitive Analysis
Nepal sourced interest payment by resident person under Section 88(1)
Legal Provision and Applicable Withholding Rate
Section 88(1): When making payment by a resident person for interest, natural resource, rent, royalty, service charge, commission, sales bonus, retirement payment and other any consideration having source in Nepal, and in making payment of amount of any retirement payment, the person shall withhold tax at the rate of 15% of the total amount of payment.
Proviso 9 to Section 88(1): In a interest payment by resident bank and financial institutions to the loan received in foreign currency from foreign banks and financial institutions to invest in the areas as specified by Nepal Rasta bank, 10% withholding rate is applicable.
Section 88(3): 5% withholding is applicable on nepal sourced non-business interest with respect to a deposit, security, debenture, government bond made to individual by
• resident BFI, cooperatives, or
• institutions issuing debentures, or
• companies listed under prevailing laws
Section 88(4)(Kha): No withholding is applicable on nepal sourced payment of interest to resident BFI.
Section 88(4)(Kha1): No withholding is applicable on nepal sourced payment of interest in respect of inter-lending of resident cooperative banks or cooperative societies.
Proviso 12 to Section 88(1): 5% withholding tax is applicable on the interest payment paid by Resident Bank and Financial Institutions to Life Insurance Companies.
Section 11(2ka): 0% withholding tax is applicable on interest payment up to Rs. 25,000 (per annum) made to deposit holders by
• rural municipality based micro finance bank
• rural development bank
• postal saving bank
• rural municipality-based saving-credit cooperatives & cooperatives whose income is derived from business mainly based on agriculture/forestry related industry/business under section 11(2)
When is it a final withholding payment?
Section 91(1)(Gna): Following interest payment, are final witholding payments, made by
• resident BFI, cooperatives, or
• institutions issuing debentures, or
• companies listed under prevailing laws
to
• Individual that are nepal sourced non-business interest
• Tax exempt entities under Section 2(dha)
Section 92(1)(Cha): Taxable payments made to non resident person under section 87, section 88, section 88Ka or section 89 are final withholding payments.
Nepal sourced natural resource payment by resident person under Section 88(1)
Legal Provision and Applicable Withholding Rate
Section 88(1): When making payment by a resident person for interest, natural resource, rent, royalty, service charge, commission, sales bonus, retirement payment and other any consideration having source in Nepal, and in making payment of amount of any retirement payment, the person shall withhold tax at the rate of 15% of the total amount of payment.
When is it a final withholding payment?
Section 92(1)(Cha): Taxable payments made to non resident person under section 87, section 88, section 88Ka or section 89 are final withholding payments.
Nepal sourced royalty payment by resident person under Section 88(1)
Legal Provision
Section 88(1): When making payment by a resident person for interest, natural resource, rent, royalty, service charge, commission, sales bonus, retirement payment and other any consideration having source in Nepal, and in making payment of amount of any retirement payment, the person shall withhold tax at the rate of 15% of the total amount of payment.
When is it a final withholding payment?
Section 92(1)(Cha): Taxable payments made to non resident person under section 87, section 88, section 88Ka or section 89 are final withholding payments.
Nepal sourced rent payment by resident person under Section 88(1)
Legal Provision and Applicable Withholding Rate
Section 88(1): When making payment by a resident person for interest, natural resource, rent, royalty, service charge, commission, sales bonus, retirement payment and other any consideration having source in Nepal, and in making payment of amount of any retirement payment, the person shall withhold tax at the rate of 15% of the total amount of payment.
Proviso 3 to Section 88(1): 10% withholding is applicable on aircraft lease payment.
Proviso 5 to Section 88(1): 10% withholding is applicable on nepal sourced rent payment by resident person, however
a) 1.5% withholding is applicable on vehicle rent payment to vehicle rental provider registered in VAT
b) No withholding is applicable on house rent payment to individual
c) No withholding is applicable on payment of encouragement amount (for electronic payment for goods and services made by the consumers as per the prevailing law) under Section 25(1Kha) of VAT Act 2052
Proviso 7 to 88(1): In a payment for use of satellite, bandwidth, optical fiber, tools related to communication or electricity transmission line, withholding at the rate of 10% is applicable,
When is it a final withholding payment?
Section 92(1)(Kha): Non business rent payment of land, house or goods & equipment installed in house made to individual is final withholding payment.
Section 92(1)(Ta): Payment of rent for transport vehicle rent or carriage vehicle rent to individual other than proprietorship is final withholding payment.
Section 92(1)(Cha): Taxable payments made to non resident person under section 87, section 88, section 88Ka or section 89 are final withholding payments.
Nepal sourced service fee payment by resident person under Section 88(1)
Legal Provision and Applicable Withholding Rate
Section 88(1): When making payment by a resident person for interest, natural resource, rent, royalty, service charge, commission, sales bonus, retirement payment and other any consideration having source in Nepal, and in making payment of amount of any retirement payment, the person shall withhold tax at the rate of 15% of the total amount of payment.
Proviso 4 to Section 88(1): 1.5% withholding is applicable on service fee payment to
• resident VAT registered person, or
• resident VAT exempt entity
Proviso 7 to 88(1): In a payment for use of satellite, bandwidth, optical fiber, tools related to communication or electricity transmission line, withholding at the rate of 10% is applicable.
Proviso 11 to Section 88(1): 5 % withholding is applicable on the registration fee, education fee and exam fee paid to foreign school or university.
Section 88(4)(Ka1): No withholding is applicable on payment made to for articles published in newspapers.
Section 88(4)(Gha): No withholding is applicable on payment of Interregional interchange fees to credit cards issuing banks.
Proviso 8 to Section 88(1): Payment for freight service and vehicle rent for freight service, withholding is applicable at the rate of 2.5% on payment. (freight means transport/carriage of goods by truck, train, ship, or aircraft)
Proviso 10 to Section 88(1): No withholding shall be applicable in payment of incentive amount for consumer who paid their bill through electronic payment instruments like payment card, e-money(wallet), mobile banking on their purchase.
When is it a final withholding payment?
Section 92(1)(Ta): Payment of carriage service to individual other than proprietorship is final withholding payment.
Section 92(1)(Ja): Payment of meeting fee upto Rs.20,000/meeting, occasional teaching fee, question setting, answer evaluation are final withholding payments.
Section 92(1)(Cha): Taxable payments made to non resident person under section 87, section 88, section 88Ka or section 89 are final withholding payments.
Nepal sourced commission and sales bonus payment by resident person under Section 88(1)
Legal Provision and Applicable Withholding Rate
Section 88(1): When making payment by a resident person for interest, natural resource, rent, royalty, service charge, commission, sales bonus, retirement payment and other any consideration having source in Nepal, and in making payment of amount of any retirement payment, the person shall withhold tax at the rate of 15% of the total amount of payment.
Proviso 2 to Section 88(1): 5% withholding is applicable on employment commission payment by resident employment company to non-resident company.
When is it a final withholding payment?
Section 92(1)(Cha): Taxable payments made to non resident person under section 87, section 88, section 88Ka or section 89 are final withholding payments.
Nepal sourced retirement payment by resident person under Section 88(1)
Legal Provision and Applicable Withholding Rate
Section 88(1): When making payment by a resident person for interest, natural resource, rent, royalty, service charge, commission, sales bonus, retirement payment and other any consideration having source in Nepal, and in making payment of amount of any retirement payment, the person shall withhold tax at the rate of 15% of the total amount of payment.
Section 88(1)(1): 5% withholding is applicable on retirement payment gain (RPG) under section 65(1)(Kha) for retirement payment (RP) by GON or contributory retirement payment made by ARF.
RPG = RP-D-MAX[500000,(RP-D)×50%] where D refers to the RP and Interests accumulated until 2058.12.18
Section 88(2)(Ga): 5% withholding rate applicable applied on the RPG for RP made by URF.
RPG = RP-RC-D, where RC refers to Retirement Contribution and D refers to the RP and Interests accumulated until 2058.12.18
When is it a final withholding payment?
Section 92(1)(Chha): RP made by GON/ARF/UARF and all other RP (except for regular pension received under pension scheme) are final withholding payment.
Section 92(1)(Gha): Payment of gain from interest in UARF by resident person is final withholding payment.
Section 92(1)(Cha): Taxable payments made to non resident person under section 87, section 88, section 88Ka or section 89 are final withholding payments.
Nepal sourced dividend payment by resident person under Section 88(2)(Ka)
Legal Provision and Applicable Withholding Rate
Section 88(2): A resident person shall, in making following payment having source in Nepal, withhold tax at the following rate: (a) In a dividend payment, at the rate of 5% of amount.
Section 11(2): 0% withholding is applicable on dividend payment by rural municipality based saving-credit cooperatives & cooperatives whose income is derived from business mainly based on agriculture/forestry related industry/business under section 11(2).
Section 11(3Ka)(Ga): 0% and 2.5% withholding is applicable on dividend payment by industries in SEZ for first 1-5th and 6-8th years of operation respectively.
Section 11(3Tha): 0% withholding is applicable on capitalization of profit for capacity increment by special industries, tourism service industry.
Proviso 6 to Section 88(1): 5% withholding is made on payment of returns by mutual fund to individual.
When is it a final withholding payment?
Section 92(1)(Ka): Dividend paid by resident company or resident partnerships are final withholding payments.
Section 92(1)(Wyan): Returns paid to individual by mutual fund are final withholding payments.
Section 92(1)(Cha): Taxable payments made to non resident person under section 87, section 88, section 88Ka or section 89 are final withholding payments.
Nepal sourced investment insurance returns payment by resident person under Section 88(2)(Kha)
Legal Provision and Applicable Withholding Rate
Section 88(2): A resident person shall, in making following payment having source in Nepal, withhold tax at the following rate: (b) In a benefit payment of investment insurance, at the rate of 5% of paid amount.
When is it a final withholding payment?
Section 92(1)(Ga): Investment insurance returns payment made by resident person is final withholding payment.
Section 92(1)(Cha): Taxable payments made to non resident person under section 87, section 88, section 88Ka or section 89 are final withholding payments.
General Exceptions to Section 88
Section 88(4): Withholding under Section 88 shall not apply to the following payments:
(a) Any other payment other than that related to the operation of a business by an individual,
(c) Payment enjoying tax exemption or payment liable to tax withholding pursuant to Section 87,
उदाहरण १६.२.५२ः मानौं, गोबिन्द भन्ने व्यक्तिले आफ्नो घर रु.५० लाखमा निर्माण गर्ने गरी निर्माण कम्पनीलाई ठेक्का दिएको रहेछ । यसरी दिएको ठेक्काको भुक्तानीमा निज गोविन्दले भुक्तानीमा कर कट्टा गर्नु पर्दैन । तर, सो निर्माण कम्पनीले यसरी ठेक्का बापत प्राप्त रकमलाई भने आफ्नो आयमा समावेश गर्नु पर्दछ ।
उदाहरण १६.२.५३ः मानौं, नेपाल अवकाश कोष, विभागबाट स्वीकृत अवकाश कोष रहेछ । उक्त कोषको निक्षेप शुभ बैंक लि. मा रहेछ । अवकाश कोषको ब्याजमा आय कर नलाग्ने भएको हुँदा सो बैंकले उक्त कोषलाई भुक्तानी गर्ने ब्याजमा कर कट्टा गर्नु पर्दैन ।
Red Flags to Section 88
1
. Let’s see what Section 88(1) states: बासिन्दा व्यक्तिले नेपालमा स्रोत भएको ब्याज, प्राकृतिक स्रोत, भाडा, रोयल्टी, सेवा शुल्क, कमिशन, बिक्री बोनस, अवकाश भुक्तानी र अन्य कुनै प्रतिफल तथा अवकाश भुक्तानीको रकम भुक्तानी गर्दा कुल भुक्तानी रकमको पन्ध्र प्रतिशतका दरले कर कट्टी गर्नु पर्नेछ । What is the problem here? The problem here is that application of 15% withholding under Section 88(1) may very well extend to any payments having source in Nepal as it states “अन्य कुनै प्रतिफल भुक्तानी” as well. This definitely is not an exhaustive list. The wording of “any other consideration” clearly indicates that IRD has reserved to withhold taxes on any consideration paid by from resident person that has source in Nepal. To know about what payments are sourced in Nepal see my other blog here: Income Sourced In Nepal: Definitive Analysis
Withholding Taxes under Section 88Ka
Please see the provisions, discussion and red flags relating to Section 88Ka here in my other blog: Windfall Gain Tax in Nepal in detail.
Withholding Taxes under Section 89
Contract payment by resident person to resident person under 89
Legal Provision and Applicable Withholding Rate
Section 89(1): In making payment of a sum exceeding Rs. 50,000 for payment of deed or contract, a resident person shall withhold tax at the rate of 1.5% of the total amount of payment.
Section 89(2): The amount referred to in Section 89(1) shall be fixed also by adding any other payments, if any, made by such person or his associated person under the same contract to the person or his associated person entitled to payment under that contract in the past ten days.
Section 89(3A): Tax shall be withheld at the rate of 1.5% from payment of amount exceeding Rs. 5,000,000 for a work to be performed by a consumers’ committee.
When is it a final withholding payment?
Section 92(1)(Cha): Taxable payments made to non resident person under section 87, section 88, section 88Ka or section 89 are final withholding payments.
Contract payment by resident person to non resident person under 89
Legal Provision and Applicable Withholding Rate
Section 89(3): Notwithstanding anything contained in sub-section (1), tax shall be withheld as follows from payment made by any resident person to any non-resident person under any deed or contract:
(a) Deed or contract, 5%,
(b) For a commission in payment of a premium to a nonresident insurance company or a premium amount received for reinsurance from a non-resident insurance company, 1.5%,
(c) Where the Department has given that resident person a notice in writing except as referred to in clause (a) or (b), at the rate specified in the notice.
Section 89(4): Notwithstanding anything contained in Section 89(1), thisSection shall not apply to the following payments:
(a)188 Any other payment except rent paid for a land or house having source in
Nepal or goods and equipment installed in the house to an individual other
than that operating a business,
(b) Payments enjoying tax exemption or payments liable to tax withholding pursuant to Section 87, 88 or 88A.
When is it a final withholding payment?
Section 92(1)(Cha): Taxable payments made to non resident person under section 87, section 88, section 88Ka or section 89 are final withholding payments.
General Exceptions to Section 89
Section 89(4): Notwithstanding anything contained in sub-section (1), this Section shall not apply to the following payments:
(a) Any other payment except rent paid for a land or house having source in Nepal or goods and equipment installed in the house to an individual other than that operating a business,
(b) Payments enjoying tax exemption or payments liable to tax withholding pursuant to Section 87, 88 or 88A.
उदाहरण १६.५.३ः मानौं, कल्पना एण्ड सन्स् प्रा.लि.ले मू.अ.कर प्रयोजनको निमित्त दर्ता भएको दिनेस सप्लायर्सबाट रु.१,००,०००।– को सामानकोठेक्का वा करार अन्र्तगत आपूर्ति लिएको रहेछ । उक्त रकम भुक्तानी गर्दा कल्पना एण्ड सन्स्प्रा.लि.ले स्रोतमा कर कट्टा नगरी भुक्तानी गरेको रहेछ । दिनेस सप्लायर्सको भुक्तानीमा कर कट्टा नगरेको भए तापनि कल्पना एण्ड सन्स् प्रा.लि.ले सो भुक्तानी बापत १.५ प्रतिशतले हुन आउने कर रकम अर्थात रु.१,५००।– कट्टी गरिएको मानिनेछ ।
Red Flags to Section 89
1. What is the meaning of deed or contract? Explanation: For the purpose of this Section “deed or contract” means a contract or agreement concluded for the supply of any goods or labors or construction, installation or establishment of tangible property or structure and such act as specified to be a deed or contract by the Department, and such contract or agreement also includes payment for the service related to construction, installation or establishment, if such service is also covered by it. स्पष्टीकरणः यस दफाको प्रयोजनको लागि “ठेक्का वा करार” भन्नाले कुनै वस्तु वा श्रमिकको आपूर्ति वा मूर्त सम्पत्ति वा संरचनाको निर्माण वा जडान वा स्थापना गर्ने सम्बन्धमा गरिएको करार वा सम्झौता तथा विभागले ठेक्का वा करार भनी तोकेको कार्यलाई सम्झनु पर्छ र त्यस्तो करार वा सम्झौताले निर्माण वा जडान वा स्थापनासँग सम्बन्धित सेवा समेतलाई समेटेको भए सो सेवा बापतको भुक्तानीलाई समेत जनाउँछ । The meaning of deed/contract, the disregard of Section 89 to source based taxation principle and disregard to taxation of foreign enterprise to the extent attriubtable to its PE is discussed in detail here in my other blog. TDS on Payment for Goods: Nepal Tax Perspective
As per Income Tax Directive: ऐनको उपरोक्त परिभाषा ऐनको दफा ८९ को प्रयोजनका लागि अर्थात ठेक्का वा करारमा अग्रिम कर कट्टी गर्ने प्रयोजनका लागि गरिएको भए पनि सो परिभाषा करार ऐनले गरेको करारको परिभाषासँग नबाझिएको र आयकर ऐनको अन्य कुनै दफाले करारको छुट्टै परिभाषा नगरेको हुँदा आयकर ऐन र यस निर्देशिकाको प्रयोजनका लागि करारको उक्त परिभाषा नै सान्दर्भिक र आधिकारिक रहेको मान्नु पर्दछ । ऐनको उपरोक्त व्यवस्था अनुसार करारले कुनै वस्तु वा श्रमिकको आपूर्ति सम्बन्धमा भएको सम्झौता वा कुनै मूर्त सम्पत्ति वा संरचनाको निर्माण वा जडान वा स्थापना गर्ने वा सो सम्बन्धी सेवा प्रदान गर्ने सम्बन्धमा गरिएको कुनै पनि प्रकारको लिखित वा मौखिक सम्झौतालाई जनाउछ । ऐनको उपरोक्त व्यवस्थामा विभागले करार भनी तोकेको कार्य पनि करार अन्तर्गत पर्ने विभागले हालसम्म करार अन्तर्गत पर्ने भनी उपरोक्त परिभाषामा उल्लिखित कार्य बाहेक अन्य कुनै कार्यलाई तोकेको छैन । यस अवस्थामा आयकर ऐन र यस निर्देशिकाको प्रयोजनका लागि करार भन्नाले कुनै वस्तु वा श्रमिकको आपूर्ति गर्ने सम्बन्धमा भएको सम्झौता, कुनै मूर्त सम्पत्ति वा संरचनाको निर्माण वा जडान वा स्थापना गर्ने सम्बन्धमा भएको सम्झौता र कुनै मूर्त सम्पत्ति वा संरचनाको निर्माण वा जडान वा स्थापना गर्ने सिलसिलामा आवश्यक पर्ने कुनै सेवा प्रदान गर्ने सम्बन्धमा भएको सम्झौतालाई सम्झनु पर्दछ । What a indeterminate tautological literature from Income Tax Directive !! Pick a side IRD !!