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    <title>2024 (2) TMI 640 - ITAT DELHI</title>
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    <description>Receipts from freight and logistics support services, reimbursement of global account management charges, and reimbursement of lease line charges were analysed under the Act and the India-USA DTAA. The Tribunal followed its earlier rulings in the assessee&#039;s own case, noting no change in facts or law and no contrary binding precedent. On that basis, freight and logistics support receipts were not treated as fee for technical services or fee for included services, global account management reimbursements were likewise outside that characterisation, and lease line charges were not regarded as royalty. The disputed additions were therefore deleted, giving the assessee complete relief on the characterisation issues.</description>
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      <title>2024 (2) TMI 640 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=449489</link>
      <description>Receipts from freight and logistics support services, reimbursement of global account management charges, and reimbursement of lease line charges were analysed under the Act and the India-USA DTAA. The Tribunal followed its earlier rulings in the assessee&#039;s own case, noting no change in facts or law and no contrary binding precedent. On that basis, freight and logistics support receipts were not treated as fee for technical services or fee for included services, global account management reimbursements were likewise outside that characterisation, and lease line charges were not regarded as royalty. The disputed additions were therefore deleted, giving the assessee complete relief on the characterisation issues.</description>
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      <pubDate>Fri, 09 Feb 2024 00:00:00 +0530</pubDate>
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