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2001 (2) TMI 299 - ITAT MADRAS-CExtract: .......g to Article X(k) the fees for technical services is to be taxed in the Contracting State and in the instant case, it would be India. We are therefore of the opinion that Rs. 2,02,237 is taxable in India as fees for technical services and we hold accordingly. The issue therefore is decided in favour of the appellant company and against the revenue.
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