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FTS should be taxable as per Article 7 in case there is no FTS clause in India-Philipines DTAA: ITAT

December 17, 2018[2018] 100 taxmann.com 230 (Bangalore - Trib.)

IT/ILT : There being no provision in DTAA to tax fees for Technical Services, payment made by assessee to avail technical service of its AE, would be taxed as per article 7 but in absence of PE in India, said income was not chargeable to tax in India

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