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The Tribunal held that the receipts were taxable in India as Fee for Technical Services (FTS) under Article 12 of the India-Germany DTAA and Section 9(1)(vii) of the Act, as they were not effectively connected to the PE. The Tribunal also upheld the taxation of interest on income tax refund as business profits effectively connected to the PE.
Showing 451–451 of 451 · Page 10 of 10
