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2008 (2) TMI 465 - AT - Income TaxExtract: ....... PE. Thus, cannot be related to art. 12.5 of the DTAA. 31. In view of our discussion we hold that interest received by the assessee on delayed issue of refunds could be taxed only under art. 12.2 of the DTAA. 32. Therefore, the appeal filed by the assessee is allowed. In the result, Departmental appeal is dismissed and assessee s appeal is allowed.
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