UAE Company Entitled to India-UAE Tax Treaty Benefits; Article 29 Limitations Do Not Apply Per Article 4(1)(b).

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....Benefits of India UAE Double Taxation Avoidance Agreement - the assessee company is a resident of the UAE, in terms of requirements of article 4(1)(b) of the Indo-UAE tax treaty, that the limitation of benefits provisions of article 29 of the Indo-UAE tax treaty cannot be pressed into service in this case, and that the assessee is eligible for treaty protection, in respect of its income earned in India, under the Indo UAE tax treaty. - AT....