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    <title>2024 (10) TMI 699 - ITAT DELHI</title>
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    <description>The ITAT Delhi ruled in favor of the assessee on multiple tax deduction issues. Regarding bandwidth charges paid to foreign telecom providers, the tribunal held these cannot be treated as royalty under section 9(1)(vi), following the Delhi HC decision in Telstra Singapore case, thus no tax deduction at source was required. For annual maintenance charges paid to foreign companies, the matter was remanded to the Assessing Officer to examine whether services qualify as technical/managerial/consultancy services, as this preliminary issue was not properly examined earlier. On agency fees paid to foreign banks, the tribunal upheld the FAA&#039;s finding that since Indian branches played no role in loan arrangements, no tax deduction obligation arose.</description>
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    <pubDate>Wed, 09 Oct 2024 00:00:00 +0530</pubDate>
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      <title>2024 (10) TMI 699 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=760100</link>
      <description>The ITAT Delhi ruled in favor of the assessee on multiple tax deduction issues. Regarding bandwidth charges paid to foreign telecom providers, the tribunal held these cannot be treated as royalty under section 9(1)(vi), following the Delhi HC decision in Telstra Singapore case, thus no tax deduction at source was required. For annual maintenance charges paid to foreign companies, the matter was remanded to the Assessing Officer to examine whether services qualify as technical/managerial/consultancy services, as this preliminary issue was not properly examined earlier. On agency fees paid to foreign banks, the tribunal upheld the FAA&#039;s finding that since Indian branches played no role in loan arrangements, no tax deduction obligation arose.</description>
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      <pubDate>Wed, 09 Oct 2024 00:00:00 +0530</pubDate>
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