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2011 (11) TMI 804 - AUTHORITY FOR ADVANCE RULINGS (INCOME TAX), NEW DELHIExtract: .......09 filed by MA does not arise. Article 14.6 has application only if Article 14.5 has no application. Hence, we are not inclined to consider the question whether controlling interest is an asset that would be taxable in France under Article 14.6 of the Treaty. 40. Accordingly, the ruling is pronounced on this 28th day of November, 2011. 1263 ITR 706
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