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of Disallowance u/s 40(a)(ia) - failure to deduct TDS u/s 195 - in view of Protocol between India and Spain, the restrictive meaning of ‘Fee for Technical Services’ appearing in Article 13(4) (c ) Indo-UK DTAA must be read as forming part of Indo-Spain DTAA, hence fabric testing would not constitute fee for technical services and consequently, no TDS required u/s 195
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