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    <title>2013 (11) TMI 419 - ITAT MUMBAI</title>
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    <description>Service tax collected by the assessee and remitted to the Government was held not to be consideration for technical services and not part of receipts chargeable as fees for technical services under section 115A read with the treaty. The amount was treated as a statutory levy collected on behalf of the Government, with no profit element and no character of trading receipt or taxable income in the assessee&#039;s hands. A contrary sales-tax based argument was distinguished, and the assessee succeeded on the issue.</description>
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      <pubDate>Wed, 25 Apr 2012 00:00:00 +0530</pubDate>
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