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'Tax' defined in article 2 of India-UAE DTAA is inclusive of income-tax, cess & surcharge: ITAT

May 3, 2019[2019] 104 taxmann.com 380 (Hyderabad - Trib.)

IT/ILT: Education cess being an additional surcharge cannot be levied in respect of tax liability under article 2 of India UAE DTAA

IT/ILT: Since provisions of articles 11 and 12 find precedence over provisions of Income Tax Act and restrict taxability at rates specified in respective articles, tax liability on royalty income and interest income could not be enhanced by including surcharge and education cess separately

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