M/S. CASTLEWICK FZE,DUBAI vs. ACIT,INTERNATIONAL TAXATION, CIRCLE-1(1), CHENNAI

In the result, the appeal filed by the assessee is allowed

gains, etc. There is no specific Article dealing with\n'FTS'.\nArticle 23 – deals with the taxability of other income, i.e. items of income\nnot dealt with in the foregoing Articles of the DTAA i.e. 6to 22. As\npointed out by the learned Authorised Representative, Article 23 would\ncover incomes like alimony, income from gambling, lottery etc. The\nclassification