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1994 (5) TMI 46 - AT - Income TaxExtract: .......ct, the provisions of the treaty would have to prevail. In the light of this discussion, what emerges is that in the case of a non-resident, who is a resident of Germany, income arising to him in India by way of royalties or technical charges could be taxed in India but that could be only on the receipt basis. 5. In the result, appeal is dismissed.
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