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of TDS u/s 195 - Payment of royalty under India – Netherlands Double Taxation Avoidance Agreement - aircraft maintenance cost - the entire repair work was carried out outside India, therefore, the assessee had no liability to deduct tax as the income was not taxable in India. Insofar as the expenses on Logo printing, the revenue has failed to demonstrate that the make available condition under Article 12(4B) of the Treaty is fulfilled. - AT
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