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of Accrual of income in India - Fees for technical services (FTS) - taxability of receipts towards Human Resource and Leadership training provided by the assessee to its Indian affiliate - once two sovereigns have added Protocol to the DTAA between India and Sweden, which contains the Most Favoured Nation (MFN) clause, inter alia, qua Article 12, the sequitur is that the beneficial provisions contained in the DTAA between India and Portuguese is to be read in the DTAA between India and Sweden. - AT
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