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2011 (1) TMI 126 - AT - Income TaxConsultancy services considered as ‘included services’ within the meaning of Article 12 of Indo Canada Treaty - whether the same could be taxed under Article 7 of the Treaty as business income - AO had not examined the issue of PE as he had taxed the income under Article 12(4)(b) and not under Article 7 - income is not taxable as "fees for included services" as in that case taxability as business profit under Article 7 is required to be seen for which PE is relevant - order of CIT(A) set aside and restore the matter back to him for passing a reasoned and speaking order giving clear finding as to the nature of services rendered by the assessee - appeal of the revenue allowed
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