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    <title>1988 (3) TMI 112 - ITAT DELHI-B</title>
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    <description>The Tribunal determined that the payments received by the non-resident company were classified as royalties and not fees for technical services. As the payments were not lump sum and did not meet the exemption criteria, they were deemed taxable under section 9(1)(vi) of the Income-tax Act. The CIT (Appeals) was found to have erred in exempting these payments, leading to the allowance of departmental appeals.</description>
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