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    <title>2021 (12) TMI 543 - ITAT DELHI</title>
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    <description>The Tribunal ruled in favor of the assessee, overturning disallowances under section 40(a)(i) of the Income-tax Act and rejecting the characterization of network and administrative support charges as Fee for Technical Services under section 9(1)(vii) of the Act. The Tribunal found the services provided were standard and did not involve human intervention, thus not qualifying as technical services. Penalty proceedings under Section 271(1)(c) were also dismissed, as the services were deemed standard and similar to a previous assessment year where disallowance was deleted. The appeals of the assessee were allowed, indicating that penalty proceedings were unwarranted.</description>
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      <title>2021 (12) TMI 543 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=415777</link>
      <description>The Tribunal ruled in favor of the assessee, overturning disallowances under section 40(a)(i) of the Income-tax Act and rejecting the characterization of network and administrative support charges as Fee for Technical Services under section 9(1)(vii) of the Act. The Tribunal found the services provided were standard and did not involve human intervention, thus not qualifying as technical services. Penalty proceedings under Section 271(1)(c) were also dismissed, as the services were deemed standard and similar to a previous assessment year where disallowance was deleted. The appeals of the assessee were allowed, indicating that penalty proceedings were unwarranted.</description>
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