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    <title>2011 (9) TMI 754 - ITAT DELHI</title>
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    <description>Reinsurance brokerage or commission received for arranging reinsurance with foreign reinsurers was not fees for technical services under section 9(1)(vii) of the Income-tax Act or Article 13(4)(c) of the India-UK DTAA. The intermediary role involved facilitating placement of risk and coordinating proposals, but did not render technical or consultancy services that made available technical knowledge, experience, skill, know-how or processes to the Indian insurance companies. As no enduring technical capability was shown to have been passed on, the receipts were held not taxable as FTS and the addition was deleted.</description>
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