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    <title>2020 (8) TMI 672 - ITAT DELHI</title>
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    <description>The Tribunal found that the payment made by the assessee to the non-resident company was a commission payment and not a fee for technical services. It concluded that the disallowance made by the Assessing Officer and enhanced by the Commissioner of Income Tax (Appeals) was erroneous. The entire disallowance of Rs. 1,32,34,080 was deleted, and the appeal of the assessee was allowed. Additionally, the Tribunal ruled that there was no basis for charging interest under Sections 234B and 234C of the Income Tax Act. The order was pronounced in open court on August 24, 2020.</description>
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      <title>2020 (8) TMI 672 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=397729</link>
      <description>The Tribunal found that the payment made by the assessee to the non-resident company was a commission payment and not a fee for technical services. It concluded that the disallowance made by the Assessing Officer and enhanced by the Commissioner of Income Tax (Appeals) was erroneous. The entire disallowance of Rs. 1,32,34,080 was deleted, and the appeal of the assessee was allowed. Additionally, the Tribunal ruled that there was no basis for charging interest under Sections 234B and 234C of the Income Tax Act. The order was pronounced in open court on August 24, 2020.</description>
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