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2012 (5) TMI 604 - DELHI HIGH COURTExtract: .......ture? We have heard the counsel for the parties on the three questions. We have also heard counsel for the parties on whether not the payment of Rs.14,71,095/- is covered and will be "fee for included services" under Article 12 of the Direct Taxation Avoidance Agreement between India and the United States of America. Judgment is reserved.
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