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2012 (3) TMI 516 - AAR - Income TaxExtract: .......rule on question no. 1 that the amount that would be payable by the applicant to XYZ (M) would be taxable in India in terms of Article 10 of the DTAC between India and Mauritius. On question no. 2, we rule that the applicant is required to withhold tax on the proposed remittance of the proceeds to XYZ (M). 18. Accordingly, the ruling in pronounced.
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