Indian Company Payment for Services in China Taxed at 10% Under Article 12(4) of India-China DTAA.

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....Whether the payment received by the applicant from the Indian company for services rendered in China is taxable in India under Article 12(4) of DTAA between India and China? - contrast with China-Pakistan tax Treaty - Held Yes - The rate of tax is 10% on the gross amount under the DTAA. - AAR....