India-Canada DTAA: ONGC's Training and Research Partnership Makes Technical Fees Taxable in India.

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....Fees for technical services - made available or not - The contention that the technology is not made available to ONGC is incorrect as the agreement not only contemplates participation but also training and collaborative research between the personnel of the non-resident and ONGC - Taxable in India as per India-Canada DTAA - AT....