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    <description>The Applicant&#039;s request for an advance ruling on the application of the India-Hungary Tax Treaty regarding dividend payments to a specific company was accepted by the Authority. The Authority found that the application was admissible despite pending assessment proceedings for the relevant year. The Revenue&#039;s argument of tax avoidance was dismissed as there was no evidence of improper means to avoid tax in the transaction. The Authority allowed the original three questions for ruling but deferred consideration of additional queries to a later hearing, emphasizing the need for the Principal CIT&#039;s input.</description>
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      <description>The Applicant&#039;s request for an advance ruling on the application of the India-Hungary Tax Treaty regarding dividend payments to a specific company was accepted by the Authority. The Authority found that the application was admissible despite pending assessment proceedings for the relevant year. The Revenue&#039;s argument of tax avoidance was dismissed as there was no evidence of improper means to avoid tax in the transaction. The Authority allowed the original three questions for ruling but deferred consideration of additional queries to a later hearing, emphasizing the need for the Principal CIT&#039;s input.</description>
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