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2007 (7) TMI 440 - AT - Income TaxExtract: .......a and thus section 5(2) and section 9(1)(vii) are not attracted. 26. As we have held so, the provisions of DTAA need not be gone into. As far as the other arguments of the learned counsel of the assessee are concerned, we do not go into the same, as it would be an academic exercise to do so. 27. In the result, the appeal of the assessee is allowed.
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