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    <title>2024 (6) TMI 817 - ITAT DELHI</title>
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    <description>Receipts for System Fund support fee and Technology Services Fees relating to marketing, distribution marketing, frequency marketing programme support and facility charges were held not taxable as royalty, fees for technical services, or fees for included services under the Income-tax Act and the India-USA DTAA, following earlier orders in the assessee&#039;s own case; the addition was deleted. Travel Agent Commission receipts could not be sustained without proper verification of the assessee&#039;s claim that they were mere reimbursements, especially where invoices and supporting statements had been filed and the factual examination had not been completed as directed; the matter was remanded to the assessing authority for verification and decision in accordance with law.</description>
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