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1991 (11) TMI 11 - CALCUTTA HIGH COURTExtract: .......it was first created after the coming into effect of the Convention of Double Taxation Avoidance Agreement and accordingly the provisions of article 12(2) will apply. For the reasons aforesaid, we answer the question in this reference in the affirmative and in favour of the assessee. There will be no order as to costs. SHYAMAL KUMAR SEN J.-I agree.
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