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    <title>2018 (11) TMI 1989 - ITAT MUMBAI</title>
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    <description>Commission and fees received for investment banking, underwriting and related services rendered outside India were treated as not taxable in India as fees for technical services. The Tribunal applied section 9(1)(vii) and the India-UK treaty test, noting that the same issue had already been decided in the assessee&#039;s favour for earlier years and that no contrary factual or legal distinction was shown for the year under appeal. On that settled basis and the rule of consistency, the receipts were held to fall outside the technical services charge and the addition was deleted.</description>
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      <link>https://www.taxtmi.com/caselaws?id=468133</link>
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