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    <title>2016 (12) TMI 1542 - ITAT MUMBAI</title>
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    <description>The Tribunal allowed the appellant&#039;s appeal, ruling that the income from software supply was not considered &#039;royalty,&#039; and the Indian subsidiary was not a Permanent Establishment. Reimbursement of expenses was deemed not taxable as Fees for Technical Services, and interest under Section 234B was not applicable. The issues of incorrect addition of income from prior years and non-receipt of tax credit were dismissed.</description>
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      <description>The Tribunal allowed the appellant&#039;s appeal, ruling that the income from software supply was not considered &#039;royalty,&#039; and the Indian subsidiary was not a Permanent Establishment. Reimbursement of expenses was deemed not taxable as Fees for Technical Services, and interest under Section 234B was not applicable. The issues of incorrect addition of income from prior years and non-receipt of tax credit were dismissed.</description>
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