S. 90 :Double taxation relief – Tax credit – Law firm- Independent Personal Services applies only to individuals — Tax Credit Allowed – The legal fees paid to a partnership firm of lawyers can indeed subjected to levy of tax under article 12 as exclusion clause under article 12(4) does not get triggered for payments to persons other than individuals , and the provisions of article 14 are required to be read in harmony with the provisions of article – DTAA -India -Japan [ Art , 12, 14 , 23 (2)]