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of ITAT, following a Co-ordinate Bench decision in the appellant's own case for earlier assessment years and finding no material change in facts or law under the Act and the India-Netherlands DTAA, held that network fees characterized by the AO as fees for technical services and royalties do not constitute taxable income in the hands of the appellant. The Tribunal deleted the addition made by the AO in respect of receipt of network fees from the Indian entity and allowed grounds 1 and 2 raised by the appellant. The determination was grounded on treaty and domestic law analysis and relevant precedential findings.
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