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    <title>1994 (5) TMI 46 - ITAT BOMBAY-E</title>
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    <description>Fees for technical services paid to a German non-resident were treated as taxable in India only on receipt basis under the applicable tax treaty. Where the treaty specifically governed such income and its scheme conflicted with the domestic rule taxing income accruing or arising to a non-resident, the treaty prevailed and the domestic accrual basis was not applied. The reported result was that the assessee succeeded on the receipt-basis issue, and the treaty-based order was left undisturbed.</description>
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      <link>https://www.taxtmi.com/caselaws?id=59317</link>
      <description>Fees for technical services paid to a German non-resident were treated as taxable in India only on receipt basis under the applicable tax treaty. Where the treaty specifically governed such income and its scheme conflicted with the domestic rule taxing income accruing or arising to a non-resident, the treaty prevailed and the domestic accrual basis was not applied. The reported result was that the assessee succeeded on the receipt-basis issue, and the treaty-based order was left undisturbed.</description>
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      <pubDate>Fri, 13 May 1994 00:00:00 +0530</pubDate>
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