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    <title>2023 (3) TMI 1024 - ITAT MUMBAI</title>
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    <description>The Tribunal allowed the appeal filed by the assessee concerning the treatment of payments made to its parent company as fees for technical services. It was held that the payments were not subject to disallowance under section 40(a)(i) of the Income Tax Act as they were reimbursements of actual expenses and not fees for technical services. Consequently, the revenue failed to establish the income element required under sections 195 and 9 of the Act, leading to the appeal being allowed.</description>
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      <description>The Tribunal allowed the appeal filed by the assessee concerning the treatment of payments made to its parent company as fees for technical services. It was held that the payments were not subject to disallowance under section 40(a)(i) of the Income Tax Act as they were reimbursements of actual expenses and not fees for technical services. Consequently, the revenue failed to establish the income element required under sections 195 and 9 of the Act, leading to the appeal being allowed.</description>
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