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    <title>2014 (3) TMI 1249 - ITAT MUMBAI</title>
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    <description>Receipts from investment banking services and expense reimbursements were held not to constitute fees for technical services under the India-UK DTAA because the services did not make available technical knowledge, experience, skill or know-how to the recipient, so the treaty position prevailed over the domestic rate. Interest income was required to be taxed at the applicable DTAA rate once treaty protection applied, and the Assessing Officer was directed to recompute consequential interest under sections 234B and 234D after giving effect to the main income determination. The alleged refund order issue was remanded to the Assessing Officer for factual verification and appropriate relief after hearing the assessee.</description>
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      <title>2014 (3) TMI 1249 - ITAT MUMBAI</title>
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      <description>Receipts from investment banking services and expense reimbursements were held not to constitute fees for technical services under the India-UK DTAA because the services did not make available technical knowledge, experience, skill or know-how to the recipient, so the treaty position prevailed over the domestic rate. Interest income was required to be taxed at the applicable DTAA rate once treaty protection applied, and the Assessing Officer was directed to recompute consequential interest under sections 234B and 234D after giving effect to the main income determination. The alleged refund order issue was remanded to the Assessing Officer for factual verification and appropriate relief after hearing the assessee.</description>
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