IPCL/Link Charges Deemed Non-Taxable, Not Royalties Under Article 12 of Tax Treaty in Recent Ruling.
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....Addition on account of IPCL/link charges - the payment is in the nature of reimbursement of expenses and accordingly not taxable in the hands of the assessee - said payments do not constitute Royalty under the provisions of Article 12 of the tax treaty - AT....
TaxTMI