Testing Services Under India-Finland DTAA Deemed Taxable in India Due to Service Utilization in Indian Territory.

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....Income taxable in India - taxability of testing services as FTS - India-Finland DTAA - the payment in question is not for the process but was for the results of testing which is used in India. The argument of the Ld. D/R that these services were availed in India and hence are taxable in India has to be upheld. - AT....