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2008 (9) TMI 410 - ITAT DELHI-BExtract: .......o been held that para 6 of art. 12 of DTAA betweenIndiaandUKwill only apply when it can be shown that the assessee carries on business inIndiaand interest arose through a PE inIndia. Accordingly, the assessee is not entitled to be taxed under para 2 of art. 12 but was rightly taxed under para 6 of art. 12. 8. In the result, the appeal is dismissed.
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