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    <title>2014 (7) TMI 1167 - ANDHRA PRADESH HIGH COURT</title>
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    <description>The Tribunal ruled in favor of the taxpayer on all issues raised in the case. It found that disallowance under Section 40(a)(i) of the Income Tax Act 1961 did not apply to software licenses acquired due to the absence of business operations in India by the supplier. Additionally, royalty payments were not deemed payable under the Indo Netherlands treaty. The exclusion of communication charges from Export Turnover under Section 10A was upheld, as was the eligibility for foreign exchange fluctuation deduction under the same section. Lastly, the Tribunal&#039;s decision to allow interest at LIBOR + 2% for outbound loans was deemed legally acceptable, resulting in the dismissal of the appeal without costs.</description>
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    <pubDate>Fri, 25 Jul 2014 00:00:00 +0530</pubDate>
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      <title>2014 (7) TMI 1167 - ANDHRA PRADESH HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=177923</link>
      <description>The Tribunal ruled in favor of the taxpayer on all issues raised in the case. It found that disallowance under Section 40(a)(i) of the Income Tax Act 1961 did not apply to software licenses acquired due to the absence of business operations in India by the supplier. Additionally, royalty payments were not deemed payable under the Indo Netherlands treaty. The exclusion of communication charges from Export Turnover under Section 10A was upheld, as was the eligibility for foreign exchange fluctuation deduction under the same section. Lastly, the Tribunal&#039;s decision to allow interest at LIBOR + 2% for outbound loans was deemed legally acceptable, resulting in the dismissal of the appeal without costs.</description>
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      <pubDate>Fri, 25 Jul 2014 00:00:00 +0530</pubDate>
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