India-UK DTAA Article 13(2): Tax on Technical Service Fees Set at 15% on Gross Receipts.

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....FTS in the given case would be taxed at the beneficial rate of 15% on gross receipts as provided in Article 13(2) of the India-UK DTAA. - the tax liability borne by GRSE will also need to be grossed up for arriving at gross receipts of the Assessee and after such grossing up such receipts have to be taxed @ 15%. - AT....