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2009 (6) TMI 2 - HC - Income TaxExempted income under DTAA – Technical Fees versus Management Fees - supervision charges relating to technical management charges - tribual held that fees for technical services of U.S. $ 2,17,250 accrued under the consultancy agreement dated 23-6-1985 with Videsh Sanchar Nigam Ltd. be considered as “Industrial or Commercial Profits” and therefore exempt from taxation as per Article III(1) of the Double Taxation Avoidance Agreement between India and Sweden dated 30th July, 1958 – HC held that the amounts in question received by the assessee for executing the aforesaid work was nothing but management fees which cannot be considered as “commercial profits” under Article III of the DTAA 1958. - Decided against the assessee
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