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    <title>2022 (1) TMI 1486 - ITAT MUMBAI</title>
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    <description>Receipts from consulting and engineering services, together with common cost recharge, were examined for characterisation as fees for technical services or royalty under the India-UK DTAA. The Tribunal followed its own earlier year decision in the assessee&#039;s case and restored these issues to the Assessing Officer for fresh adjudication on merits. The tax-rate dispute was treated as already covered by the earlier year&#039;s relief, and the assessee&#039;s claim on that aspect was accepted. The overall effect was partial relief, with the DTAA characterisation questions remitted and the rate application issue resolved in the assessee&#039;s favour.</description>
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      <title>2022 (1) TMI 1486 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=461987</link>
      <description>Receipts from consulting and engineering services, together with common cost recharge, were examined for characterisation as fees for technical services or royalty under the India-UK DTAA. The Tribunal followed its own earlier year decision in the assessee&#039;s case and restored these issues to the Assessing Officer for fresh adjudication on merits. The tax-rate dispute was treated as already covered by the earlier year&#039;s relief, and the assessee&#039;s claim on that aspect was accepted. The overall effect was partial relief, with the DTAA characterisation questions remitted and the rate application issue resolved in the assessee&#039;s favour.</description>
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