Dutch Entity's Dredger Hire Income Exempt from Indian Taxation Under DTAA, Not Classified as Royalty Per Section 9.

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....Right to use any industrial, commercial or scientific equipment – Royalty u/s 9 or not - DTAA with Netherlands – the amount received by the assessee for hiring out Dredgers to an Indian Company of the same name for use in Indian Ports is not taxable in India - HC....