Income accrued in India - Executive search fee - neither taxable in the nature of ‘fee for technical...

Income accrued in India - Executive search fee - neither taxable in the nature of ‘fee for technical services’ under Article 12(5)(a) or (b) nor as ‘Royalty’ under Article 12(4) of the India-Netherlands Tax Treaty read with clause (iv) of Explanation-2 to Sec. 9(l)(vi) .....

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