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    <title>2012 (10) TMI 129 - ITAT MUMBAI</title>
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    <description>Marketing contributions were discussed as royalty, but that characterization was not pressed; the rate issue was resolved by following the assessee&#039;s earlier year order, treating such contributions as taxable at 10%. Receipts from value added services were upheld as fees for technical services because no distinguishing facts were shown, while the applicable rate issue was remanded to the Assessing Officer in line with the earlier year&#039;s directions. Royalty income was accepted as taxable at the concessional 10% rate. Interest under section 234B was held not chargeable where tax was deductible at source on royalty and fees for technical services, and recomputation was directed after reducing tax deductible at source from advance tax payable.</description>
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      <title>2012 (10) TMI 129 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=217176</link>
      <description>Marketing contributions were discussed as royalty, but that characterization was not pressed; the rate issue was resolved by following the assessee&#039;s earlier year order, treating such contributions as taxable at 10%. Receipts from value added services were upheld as fees for technical services because no distinguishing facts were shown, while the applicable rate issue was remanded to the Assessing Officer in line with the earlier year&#039;s directions. Royalty income was accepted as taxable at the concessional 10% rate. Interest under section 234B was held not chargeable where tax was deductible at source on royalty and fees for technical services, and recomputation was directed after reducing tax deductible at source from advance tax payable.</description>
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