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2004 (8) TMI 103 - AUTHORITY FOR ADVANCE RULINGSApplicant received amount of funds as a grant for funding a "feasibility study" on the proposed CNS/ATM project in India - Since the source of payment to Innovative Solutions is the grant made by the Government of the USA, the royalties/fees for included services shall be deemed to arise in the USA and subject to tax only in that State - Therefore, payments made to Innovative Solutions are not taxable in India either under the Income-tax Act or under the DTAA between India and the USA.
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