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    <title>2019 (4) TMI 308 - ITAT PUNE</title>
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    <description>The Tribunal allowed the assessee&#039;s appeal and dismissed the Revenue&#039;s appeal. It held that payments for software and database access were not taxable as royalty, and consultancy fees were not taxable as fees for technical services. As a result, the demands under sections 201(1) and 201(1A) were canceled. The issue of grossing up under section 195A was also dismissed due to the low tax effect.</description>
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      <description>The Tribunal allowed the assessee&#039;s appeal and dismissed the Revenue&#039;s appeal. It held that payments for software and database access were not taxable as royalty, and consultancy fees were not taxable as fees for technical services. As a result, the demands under sections 201(1) and 201(1A) were canceled. The issue of grossing up under section 195A was also dismissed due to the low tax effect.</description>
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