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2016 (6) TMI 1365 - SC ORDERFees for technical services received - computation of period of stay - whether taxable by reason of article 12(2) of the DTAA with Japan? - HELD THAT:- The essential question is whether Article 12(2) or 12(5) of the Agreement which is applicable in these cases. In the facts of these cases, we are not inclined to go into this aspect. The special leave petitions are, accordingly, dismissed
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