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    <title>2010 (6) TMI 647 - ITAT MUMBAI</title>
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      <description>Marketing contribution and reservation assessment fees were alleged to be royalty or fees for technical services, but the true character of the receipts depended on factual verification of how they were received and applied. Because a prior coordinate order on similar facts had already restored the matter for fresh examination, judicial discipline required the same course here. The taxability issue was therefore not finally decided on merits and was sent back to the Assessing Officer for de novo adjudication.</description>
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