Indo-Russia DTAA Dispute: Income from PDPL Project Taxed at 10% Due to Lack of Evidence from Assessing Officer.

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....Rate of tax under Indo-Russia DTAA - No case has been made out by the A.O. to show that Section 115A and Section 9(1)(vii) are not applicable in the present case as per which the income of the assessee with regard to PDPL project is liable to tax @ 10% as has been claimed by the assessee. - AT....