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    <title>2022 (10) TMI 833 - ITAT KOLKATA</title>
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    <description>Testing and other services performed in Finland were treated as taxable in India as fees for technical services under Article 12 of the India-Finland DTAA because the payment related to testing results used in India. On surcharge and education cess, the treaty rate was read as governing the tax burden, so those additions were held not leviable. The result was partial relief: the service income remained taxable in India, but the levy of surcharge and education cess was excluded.</description>
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      <description>Testing and other services performed in Finland were treated as taxable in India as fees for technical services under Article 12 of the India-Finland DTAA because the payment related to testing results used in India. On surcharge and education cess, the treaty rate was read as governing the tax burden, so those additions were held not leviable. The result was partial relief: the service income remained taxable in India, but the levy of surcharge and education cess was excluded.</description>
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