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    <title>2023 (8) TMI 296 - GUJARAT HIGH COURT</title>
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    <description>The HC dismissed the appeal, affirming the Tribunal&#039;s decision that the assessee was entitled to the benefits of the DTAA between India and USA. The Tribunal found that GIA Inc. USA was the beneficial owner of the payments, and the remittances were correctly made to its offshore bank account. Clerical errors in naming GIA Hong Kong Laboratory Ltd. did not affect this determination. The services provided did not qualify as fees for technical services under the DTAA. The HC concluded that the Tribunal&#039;s findings were based on a correct appreciation of the facts, and no substantial question of law was involved.</description>
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      <title>2023 (8) TMI 296 - GUJARAT HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=441317</link>
      <description>The HC dismissed the appeal, affirming the Tribunal&#039;s decision that the assessee was entitled to the benefits of the DTAA between India and USA. The Tribunal found that GIA Inc. USA was the beneficial owner of the payments, and the remittances were correctly made to its offshore bank account. Clerical errors in naming GIA Hong Kong Laboratory Ltd. did not affect this determination. The services provided did not qualify as fees for technical services under the DTAA. The HC concluded that the Tribunal&#039;s findings were based on a correct appreciation of the facts, and no substantial question of law was involved.</description>
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