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    <title>2023 (8) TMI 445 - ITAT MUMBAI</title>
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    <description>The Tribunal ruled in favor of the assessee, a French company, in a tax dispute concerning the taxability of various service fees under the India-France DTAA. The Tribunal directed the Assessing Officer to delete additions made towards TSIS services and management fees, holding that these were not taxable as royalty or Fees for Technical Services (FTS). The issue of taxability of guarantee fees was remitted back to the AO for fresh examination in accordance with law. The appeal was partly allowed, providing relief to the assessee on the disputed tax liabilities.</description>
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      <title>2023 (8) TMI 445 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=441466</link>
      <description>The Tribunal ruled in favor of the assessee, a French company, in a tax dispute concerning the taxability of various service fees under the India-France DTAA. The Tribunal directed the Assessing Officer to delete additions made towards TSIS services and management fees, holding that these were not taxable as royalty or Fees for Technical Services (FTS). The issue of taxability of guarantee fees was remitted back to the AO for fresh examination in accordance with law. The appeal was partly allowed, providing relief to the assessee on the disputed tax liabilities.</description>
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