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1999 (1) TMI 6 - HC - Income TaxExtract: .......n view of art. XIV(1) of the DTAA, sub-s. (2) of s. 90 of the Act and the categorical finding of the Tribunal that the remuneration in question was for the services rendered in France, we are of the clear opinion that the proposed question is not a referable question of law. 5. These applications are, therefore, rejected and the rule is discharged.
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