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    <title>2017 (11) TMI 568 - ITAT DELHI</title>
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    <description>Re-examination of whether roaming and interconnect charges qualify as fee for technical services for withholding tax purposes concluded that such charges are payments for a standard facility, involve no requisite human intervention to constitute a technical service, and therefore do not attract withholding as technical fees. The revisional jurisdiction was held improperly exercised because the revising officer acted solely on an ACIT(TDS) letter without independent satisfaction, and the original TDS officer&#039;s view was one of two permissible views after enquiry; consequently the revisionary proceedings were void and relief granted to the assessee.</description>
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      <title>2017 (11) TMI 568 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=350689</link>
      <description>Re-examination of whether roaming and interconnect charges qualify as fee for technical services for withholding tax purposes concluded that such charges are payments for a standard facility, involve no requisite human intervention to constitute a technical service, and therefore do not attract withholding as technical fees. The revisional jurisdiction was held improperly exercised because the revising officer acted solely on an ACIT(TDS) letter without independent satisfaction, and the original TDS officer&#039;s view was one of two permissible views after enquiry; consequently the revisionary proceedings were void and relief granted to the assessee.</description>
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