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2006 (11) TMI 138 - AUTHORITY FOR ADVANCE RULINGS
Agreement for information technology cost sharing with AT&S Austria - Payments made by the applicant to AT&S Austria are in the nature of fees for technical services within the meaning of Explanation 2 to clause (vii) of sub-section (i) of section 9 of the Act and article 12(4) of DTAA and therefore they would be subject to withholding of tax at source u/s195 – Question whether AT&S Austria is charging any separate fee for the secondment of the employees, is not material