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    <title>2012 (12) TMI 1153 - ITAT BANGALORE</title>
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    <description>The Tribunal upheld that payments by the assessee to M/s. Hospet Steels Limited were reimbursements, not fees for technical services, as per the profit and loss account and Strategic Alliance Agreement. It was determined that no service charges were levied by HSL, and the payments were cost-to-cost without any profit element. Consequently, the Tribunal dismissed the Revenue&#039;s appeals, affirming that the payments did not attract TDS under section 194J, aligning with the CIT (A)&#039;s decision.</description>
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      <title>2012 (12) TMI 1153 - ITAT BANGALORE</title>
      <link>https://www.taxtmi.com/caselaws?id=272405</link>
      <description>The Tribunal upheld that payments by the assessee to M/s. Hospet Steels Limited were reimbursements, not fees for technical services, as per the profit and loss account and Strategic Alliance Agreement. It was determined that no service charges were levied by HSL, and the payments were cost-to-cost without any profit element. Consequently, the Tribunal dismissed the Revenue&#039;s appeals, affirming that the payments did not attract TDS under section 194J, aligning with the CIT (A)&#039;s decision.</description>
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