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2005 (2) TMI 450 - AT - Income TaxExtract: .......agree with the view taken by the CIT(A) that the amounts payable to American company were fees for included services within the meaning of article 12(4)(b) of the DTAA with the USA and therefore liable for withholding of tax under section 195 of the Act. Accordingly, we dismiss the appeal of the assessee. 10. In the result, the appeal is dismissed.
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