Education cess is nothing but an additional surcharge & part of taxes

R.A.K. Ceramics, UAE Vs DCIT (ITAT Hyderabad) Article 2(1) of the India-UAE DTAA provides that the taxes covered shall include tax and surcharge thereon. Education cess is nothing but an additional surcharge & is also covered by the definition of taxes. Article 2(1) of the applicable tax treaty provides that the taxes covered shall include tax and surcharge thereon. Once we come to the conclusion that education cess is nothing but an additional surcharge, it is only corollary thereto  that the education cess will also be covered by the scope of Article 2. Accordingly, the provisions of Ar...