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    <title>2023 (9) TMI 1470 - ITAT DELHI</title>
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    <description>ITAT Delhi dismissed revenue&#039;s appeal regarding taxability of payments received by assessee from Indian customers for centralized services. The Tribunal held that such receipts cannot be treated as Fee for Technical Services under section 9(1)(vii) or Fee for Included Services under Article 12(4)(a) of Indo-US DTAA. Decision was based on identical ruling in assessee&#039;s own case for AY 2015-16, which was upheld by Delhi HC. The Tribunal found no grounds to interfere with first appellate authority&#039;s decision declaring centralized services receipts as not constituting FTS/FIS.</description>
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      <title>2023 (9) TMI 1470 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=314051</link>
      <description>ITAT Delhi dismissed revenue&#039;s appeal regarding taxability of payments received by assessee from Indian customers for centralized services. The Tribunal held that such receipts cannot be treated as Fee for Technical Services under section 9(1)(vii) or Fee for Included Services under Article 12(4)(a) of Indo-US DTAA. Decision was based on identical ruling in assessee&#039;s own case for AY 2015-16, which was upheld by Delhi HC. The Tribunal found no grounds to interfere with first appellate authority&#039;s decision declaring centralized services receipts as not constituting FTS/FIS.</description>
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