Levy of tax on the royalties or fees for technical services - rate of tax under the DTAA - 12% or 10% -...

Levy of tax on the royalties or fees for technical services - rate of tax under the DTAA - 12% or 10% - the substitution has the effect of deleting the old rule and making the new rule operative. Therefore, the Tribunal has rightly determined the rate of tax as substituted in Clause 2 of Article 12 of DTAA between India and Singapore applicable for the entire fiscal year as defined in DTAA and is liable to be taxed at 10%. - HC .....

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