India-France DTAA: No Extra Surcharge or Education Cess Beyond 10% Tax Cap on Royalty Income. Article 13 Applied.

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....Levy of surcharge and education over 10% tax as per the DTAA between India and France on royalty - revenue cannot levy surcharge and education cess, which is also in the nature of surcharge, over and above the cap of 10% prescribed in article 13 as the tax rate for Royalty income. - AT....