In the result, the appeal is dismissed
Bench: Shri Yogesh Kumar Us & Shri Sanjay Awasthiआ.अ.सं/.I.T.A No.250/Ddn/2025 िनधा"रणवष"/Assessment Year:2016-17 बनाम Dy. Commissioner Of Income Tax, Halliburton Worldwide Gmbh 1St Floor, Ida, 46, E.C. Road, Aayakar Bhawan, 13-A, Subhash Road, Vs. Dehradun, Uttarakhand. Dehradun- 248001,Uttarakhand. Pan No.Aadch1061Q अपीलाथ" Appellant ""यथ"/Respondent
145 taxmann.com 649 (Del – Trib.), to canvass the point that levy of surcharge and cess over and above the taxable rate of 10% on “Royalty” and FTS is not permissible as per the tax treaty provisions. 3. We have considered the arguments of Ld. DR/AR and have gone through the records before us. It is seen that the ground no.1