No Tax payable by Canadian Company on fees for included services by virtue of article 12(5)(a) of DTAA

IN THE ITAT MUMBAI BENCH ‘L’ Deputy Commissioner of Income-tax Versus Dodsal (P.) Ltd. IT Appeal No. 2624 (Mum.) of 2006 [Assessment years 2002-03] August, 29, 2012 ORDER P.M. Jagtap, Accountant Member This appeal is preferred by the Revenue against the order of learned CIT(Appeals), Central-I, Mumbai dated 13-02-2006. 2. In ground No.1 raised in this appeal as well as the additional ground filed during the course of appellate proceedings, the Revenue has challenged the action of the learned CIT(Appeals) in deleting the dis allowance of Rs. 2,69,42,412/- made by th...