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    <description>Remuneration, retainer fees and directly connected reimbursements paid to a Sri Lanka resident for sales promotion and marketing work performed in Sri Lanka were not taxable in India. The services were held not to be managerial, technical or consultancy services and therefore did not constitute fees for technical services under Explanation 2 to section 9(1)(vii) of the Income-tax Act, 1961. As the recipient was resident in Sri Lanka and the income also fell within Article 14 of the India-Sri Lanka DTAA, no tax deduction at source was required on the payments.</description>
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