Income from advisory services for hotel design in India not taxable under Indo-US tax treaty, per legal precedent.

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....Income accrued in India - sum received for advisory assistance for design and construction of hotel - Indo-US tax treaty - Amounts in question are not taxable in terms of the provisions of the applicable tax treaty and the findings of the co-ordinate bench still hold good in law, we have no reasons to take any other view of the matter than the view so taken by the coordinate bench - CIT(A) was quite justified in the following a binding judicial precedent - AT....