Fees for Technical Services Excluded from Miscellaneous Income in India-Thailand DTAA u/s 9(1)(vii.

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....Fees for technical services covered under section 9(1)(vii) or covered in DTAA between India and Thailand - transfer of know-how - technical advice / training - Since the said income does not fall as miscellaneous income, the same cannot be brought under art. 22. - HC....