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    <title>2026 (4) TMI 97 - ITAT DELHI</title>
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      <description>Receipts from title process services were held not taxable as royalty because the work only collated and provided access to public-domain property data, without transfer of commercial experience, know-how, or any right to use equipment or information; the addition was deleted. Receipts from marketing support services were held not taxable as fees for included services because the advisory and promotional functions did not make available technical knowledge, experience, skill, know-how, or processes to the recipient; that addition was also deleted. The disputed tax additions on both streams were therefore set aside, leaving the assessee with only partial relief.</description>
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