Income accrued in India - testing and other services - exception curved out to Article 12(5) of the...

Income accrued in India - testing and other services - exception curved out to Article 12(5) of the India-Finland DTAA that when the fees is paid for technical services which are performed within a contracting state does not apply as the payment in question was made for the test results which were used within India. though the process of testing may have been conducted outside India but the payment in question is not for the process but was for the results of testing - taxable in India .....

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