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    <title>2012 (12) TMI 763 - ITAT MUMBAI</title>
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    <description>The appeal was partly allowed by the Tribunal, ruling in favor of the appellant on the issues of income accrual without RBI approval and the taxability of fees for technical services under relevant tax treaties. The Tribunal held that the amount payable by BAH India to the USA entity did not constitute taxable income due to the absence of RBI approval and that fees for technical services should only be taxed when actually received, not when payable. Consequently, the additions made by the Assessing Officer were deleted.</description>
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      <title>2012 (12) TMI 763 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=219748</link>
      <description>The appeal was partly allowed by the Tribunal, ruling in favor of the appellant on the issues of income accrual without RBI approval and the taxability of fees for technical services under relevant tax treaties. The Tribunal held that the amount payable by BAH India to the USA entity did not constitute taxable income due to the absence of RBI approval and that fees for technical services should only be taxed when actually received, not when payable. Consequently, the additions made by the Assessing Officer were deleted.</description>
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      <pubDate>Fri, 21 Dec 2012 00:00:00 +0530</pubDate>
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