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    <title>2018 (12) TMI 1321 - ITAT MUMBAI</title>
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    <description>Receipts from satellite telecommunication services were analysed under the Act and the India-UK treaty and treated as business profits rather than royalty, because the treaty meaning of royalty could not be enlarged by domestic-law amendments and the services were rendered from outside India. The liaison office and Space Segment Monitoring System were not accepted as creating a permanent establishment in India, as the liaison office was limited to approved liaison functions and no sufficient business activity was proved. Credit for tax deducted at source was not finally adjudicated and was remanded for verification and allowance in accordance with law.</description>
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