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2003 (1) TMI 261 - AT - Income TaxExtract: .......e, namely, that art. 12(4)(b) is applicable and set aside his conclusion and uphold the action of the AO inasmuch as under the provisions of DTAA, the nature of the payment necessitated that tax be deducted at the rate specified. As such, the grounds raised by the Revenue are allowed. 36. In the result, the appeals filed by the Revenue are allowed.
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