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Perfetti India's Payments Taxed Under Article 12.5(a) & (b) of Double Taxation Agreement: AAR Insights on FTS Fees.

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....Double taxation Agreements - Meaning of fees for technical services (FTS) - allocated of cost - the applicant is taxable under Article 12.5(a) and as also under Article 12.5(b) - the payment made by Perfetti India would be chargeable to tax in India..... - AAR....