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2010 (6) TMI 648 - AT - Income TaxExtract: ....... within the meaning of Article 12(3) of the DTAA between India and USA. In our opinion, there is no difference in the facts and material here before us and accordingly, we follow the order of the Tribunal for assessment year 2003-04 (supra) and agree with the findings of the Id CIT(A). 7. In the result, the appeal filed by the revenue is dismissed.
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