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    <title>2017 (9) TMI 478 - ITAT MUMBAI</title>
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    <description>The Appellate Tribunal held that the consultancy fees received by the non-resident foreign company from a Chinese entity were not Fees for Technical Services (FTS) and were not taxable in India under the Indian Netherland tax treaty. The Tribunal found that the services were rendered outside India and utilized in China, making them not subject to tax in India. Consequently, the Tribunal allowed the appeal, reversing the lower authority&#039;s decision and ruling in favor of the assessee.</description>
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      <description>The Appellate Tribunal held that the consultancy fees received by the non-resident foreign company from a Chinese entity were not Fees for Technical Services (FTS) and were not taxable in India under the Indian Netherland tax treaty. The Tribunal found that the services were rendered outside India and utilized in China, making them not subject to tax in India. Consequently, the Tribunal allowed the appeal, reversing the lower authority&#039;s decision and ruling in favor of the assessee.</description>
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