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    <title>2012 (2) TMI 365 - ITAT MUMBAI</title>
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    <description>The tribunal held that the transportation fee received by the foreign company did not qualify as &quot;fees for technical services&quot; under Section 9(1)(vii) of the Income-tax Act, as the services provided were not managerial, technical, or consultancy services. Additionally, the income from the services could not be attributed to any business connection in India under Section 9(1)(i) since the services were rendered outside India. Consequently, the tribunal allowed the appeal by the assessee, concluding that the amount in question could not be taxed in India.</description>
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    <pubDate>Wed, 22 Feb 2012 00:00:00 +0530</pubDate>
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      <title>2012 (2) TMI 365 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=210937</link>
      <description>The tribunal held that the transportation fee received by the foreign company did not qualify as &quot;fees for technical services&quot; under Section 9(1)(vii) of the Income-tax Act, as the services provided were not managerial, technical, or consultancy services. Additionally, the income from the services could not be attributed to any business connection in India under Section 9(1)(i) since the services were rendered outside India. Consequently, the tribunal allowed the appeal by the assessee, concluding that the amount in question could not be taxed in India.</description>
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      <pubDate>Wed, 22 Feb 2012 00:00:00 +0530</pubDate>
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