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of Income accrued in India - professional legal services provided before a foreign court - it cannot be brought to tax as FIS under Article 12 of the India-USA DTAA, because there is no make available of any particular knowledge or skill to ONGC before the courts which can enable ONGC to represent its case in future - legal services cannot be treated as FTS as it is a professional services which is outside the scope of Section 9(1)(vii)
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