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    <description>Assessment focused on whether cross-border payments for installation, repair and market study qualify as fee for technical services; based on contract scope and technical nature, such activities were held to be technical services and treated as taxable with corresponding TDS consequences. The tribunals acceptance of the assessing officers factual appraisal of work orders was affirmed, and the earlier authority requiring that exception to taxability requires services to be utilised in business carried on outside India or that the source be situated outside India was held applicable, resulting in denial of treaty/exception relief and no interference with the tax deduction findings.</description>
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