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Income taxable in India - Addition of receipts from Industrial Liaison program (ILP) - the Appellant is only providing administrative support to the members and not rendering any technical services. It cannot be said that the Appellant is making available any technical know-how, experience, etc., or technical plan/design to the members as enumerated in Article 12 of the DTAA - Receipt from Coordination Membership Agreement do not qualify as ‘Fee for Included Services’ - AT
Income taxable in India - Addition of receipts from Industrial Liaison program (ILP) - the Appellant is only providing administrative support to the members and not rendering any technical services. It cannot be said that the Appellant is making available any technical know-how, experience, etc., or technical plan/design to the members as enumerated in Article 12 of the DTAA - Receipt from Coordination Membership Agreement do not qualify as ‘Fee for Included Services’ - AT
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