Tax limitation on royalties and technical fees: source tax capped where recipient is the beneficial owner, aligning treaty rates. The Central Government, exercising powers under section 90 of the Income-tax Act, substituted paragraph 2 of Article 13 of the India-Spain convention so that royalties and fees for technical services may be taxed in the source State but, where the recipient is the beneficial owner, the tax charged shall not exceed ten per cent of the gross amount; the amendment implements the Protocol's paragraph providing for application of a lower source-tax rate and is applicable from assessment year 2024-25.