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    <title>2012 (12) TMI 186 - ITAT, DELHI</title>
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    <description>Where the material facts and contracts remained unchanged from earlier years, the Tribunal held that it was bound by the jurisdictional High Court&#039;s decision in the assessee&#039;s own case and could not sustain a contrary view on the basis of vague, un-confronted later material. On that footing, the income from supply of telecom equipment and software was not brought to tax in India as business profits or royalty under the Indo-Swedish treaty. For the same reason, interest under section 234B was not leviable on the non-resident assessee. The additions and consequential levy therefore did not survive.</description>
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    <pubDate>Fri, 20 Jul 2012 00:00:00 +0530</pubDate>
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      <title>2012 (12) TMI 186 - ITAT, DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=219171</link>
      <description>Where the material facts and contracts remained unchanged from earlier years, the Tribunal held that it was bound by the jurisdictional High Court&#039;s decision in the assessee&#039;s own case and could not sustain a contrary view on the basis of vague, un-confronted later material. On that footing, the income from supply of telecom equipment and software was not brought to tax in India as business profits or royalty under the Indo-Swedish treaty. For the same reason, interest under section 234B was not leviable on the non-resident assessee. The additions and consequential levy therefore did not survive.</description>
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      <pubDate>Fri, 20 Jul 2012 00:00:00 +0530</pubDate>
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