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2011 (4) TMI 1469 - ITAT PUNEExtract: .......n Ground No 2 is covered in favour of the assessee and the taxation on gross basis at higher rate of 20 under section 115A read with 44D of the Act are unwarranted and taxation is ought to be at 10 on gross basis under Article 12(2) of the Tax Treaty as offered in the return of income. Accordingly, Ground No. 2 is allowed. 12. In the result, appeal
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