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    <title>2004 (5) TMI 63 - AUTHORITY FOR ADVANCE RULINGS</title>
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    <description>Amounts received from an approved superannuation fund were held taxable in India under Article 16(1) of the India-USA DTAA because the payment was received in India from a former employer and related services were rendered in India, so the treaty did not exclude Indian taxability. The claim for exemption under section 10(13) also failed because that provision applies only to payments on retirement at or after the specified age, or on incapacity before such retirement; resignation before the specified age does not satisfy that . Both issues were decided against the applicant.</description>
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      <title>2004 (5) TMI 63 - AUTHORITY FOR ADVANCE RULINGS</title>
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      <description>Amounts received from an approved superannuation fund were held taxable in India under Article 16(1) of the India-USA DTAA because the payment was received in India from a former employer and related services were rendered in India, so the treaty did not exclude Indian taxability. The claim for exemption under section 10(13) also failed because that provision applies only to payments on retirement at or after the specified age, or on incapacity before such retirement; resignation before the specified age does not satisfy that . Both issues were decided against the applicant.</description>
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