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    <title>2020 (10) TMI 654 - ITAT DELHI</title>
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    <description>The Tribunal upheld the decision of the Dispute Resolution Panel, ruling that the payments received for logistics services by the foreign company were not &quot;fees for technical services&quot; under section 9(1)(vii) of the Income Tax Act. Additionally, the receipts were not deemed to accrue or arise in India under section 9(1)(i) as the services were performed entirely outside India, leading to the dismissal of the revenue&#039;s appeal.</description>
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      <description>The Tribunal upheld the decision of the Dispute Resolution Panel, ruling that the payments received for logistics services by the foreign company were not &quot;fees for technical services&quot; under section 9(1)(vii) of the Income Tax Act. Additionally, the receipts were not deemed to accrue or arise in India under section 9(1)(i) as the services were performed entirely outside India, leading to the dismissal of the revenue&#039;s appeal.</description>
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