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2009 (3) TMI 41 - AAR - Income TaxAgreement between applicant (Foreign Co.) & Reliance industry for providing services got terminated in mid-way - Held that Engineering and Procurement services rendered fall within scope of “royalties” as defined in the DTAA and receipts are taxable in India by virtue of Art. XII(2). Under the Act too, they are taxable - However, receipts from Project & Management Services, shall be treated as business income & be taxable only to the extent they are attributable to the operations of PE in India
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