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    <description>Receipts not attributable to the assessee&#039;s permanent establishment were examined for taxability in India as fees for technical services under Article 13 of the India-United Kingdom tax treaty. The Tribunal treated the issue as already covered by earlier coordinate bench decisions in the assessee&#039;s own case for prior assessment years, and the parties accepted that the same factual and legal controversy arose again. Following the earlier view, the Tribunal declined to take a different view on the disputed receipts and held them taxable in India, deciding the issue against the assessee and in favour of the Revenue.</description>
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      <link>https://www.taxtmi.com/caselaws?id=297796</link>
      <description>Receipts not attributable to the assessee&#039;s permanent establishment were examined for taxability in India as fees for technical services under Article 13 of the India-United Kingdom tax treaty. The Tribunal treated the issue as already covered by earlier coordinate bench decisions in the assessee&#039;s own case for prior assessment years, and the parties accepted that the same factual and legal controversy arose again. Following the earlier view, the Tribunal declined to take a different view on the disputed receipts and held them taxable in India, deciding the issue against the assessee and in favour of the Revenue.</description>
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