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    <title>2012 (11) TMI 1130 - ITAT HYDERABAD</title>
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    <description>A bona fide and reasonable explanation for a 175-day delay in filing appeals was accepted, and the delay was condoned. Reimbursed expenditure was treated as outside the scope of taxable income because the same issue had already been decided in the assessee&#039;s favour on identical facts in earlier years. Receipts from projects commenced before 1.4.2003 were treated as fees for technical services under the applicable tax treaty and not as business profits, so they were taxable at 15% rather than 20%. The note reflects application of prior-year findings to substantially similar issues.</description>
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      <description>A bona fide and reasonable explanation for a 175-day delay in filing appeals was accepted, and the delay was condoned. Reimbursed expenditure was treated as outside the scope of taxable income because the same issue had already been decided in the assessee&#039;s favour on identical facts in earlier years. Receipts from projects commenced before 1.4.2003 were treated as fees for technical services under the applicable tax treaty and not as business profits, so they were taxable at 15% rather than 20%. The note reflects application of prior-year findings to substantially similar issues.</description>
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