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2005 (2) TMI 457 - AT - Income TaxExtract: .......For the above reasons, we hold that it was in fact the Government of India which paid the royalty and, therefore, the tax payable is only 15 per cent as per art 13.2(i)(aa) of the DTA betweenIndiaandUK. 7. In the result, the appeal of the assessee for the asst. yr 1997-98 is allowed and that of the Department for the asst. yr. 1998-99 is dismissed.
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