Reassess TDS Non-Deduction on Royalties: Examine MFN Clause in Indo-Belgium DTAA for Article 12 Override.

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....Addition u/s 40(a)(i) - Royalties and fees for technical services - non-deduction of TDS on the commission payment - scope of MFN clause - ITAT directed the Assessing Officer to examine the MFN clause available in the Protocol of Indo-Belgium DTAA as to whether the same shall override the specific provisions laid down under Article 12 and decide the issue afresh in accordance with law.....