AHL's 1.5% contribution for marketing, Rs. 38.59 lacs, not classified as 'royalties' under DTAA Article 12.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....When admittedly contribution at the rate of 1.5% by AHL to the assessee, amounting to Rs. 38.59 lacs, is towards marketing activities, it can not be characterized as 'royalties' falling within the ambit of Article 12 of the DTAA - AT....