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2007 (1) TMI 109 - AAR - Income TaxApplicant, an investment company incorporated in Netherlands, invests in software products, development & carries on its operations through various subsidiaries across the globe - capital gain arising to the applicant in the course of corporate reorganization at the group level, from the proposed transfer of shares - held that no taxes need be deducted at source in this case, since the capital gains in question would not be liable to tax under the provisions of the Act read with DTAA
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