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2004 (3) TMI 54 - KARNATAKA HIGH COURTDouble Taxation Avoidance Agreement between the Republic of India and the Federal Republic of Germany - "1. Whether Tribunal was right in holding that the engineering fees received/receivable by the assessee was in the nature of fees for technical services in accordance with the definition of 'fees for technical services' as given in clause (4) of article VIIIA of the amended DTAA? - 2. Whether, Tribunal Was right in holding that the engineering fees received/receivable by the assessee could also be considered as falling within the definition of 'fees for technical services' even in terms of the provisions of section 9(1)(vii)? - All the questions are answered in affirmative against the assessee and in favour of the Revenue
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