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2005 (9) TMI 27 - AAR - Income TaxApplicant, a company registered under the Indian Companies – owner of mines - material analysed and tested in the laboratory in Canada - For technical services rendered outside India the consultant and the lab fees are paid by the applicant in dollars in Canada – held that services rendered by the Met-Chem Inc., Canada is considered to be rendered in India – held that the rate of tax applicable for the purpose of TDS would be the lesser of the rates prescribed under Finance Act or in the treaty
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