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    <description>Overseas investment banking services rendered outside India were not taxable in India merely because the benefit of the transactions accrued to Indian companies. The Tribunal held that the receipts did not constitute fees for technical services under the Income-tax Act where the services were performed outside India and the treaty requirement of making available technical knowledge, experience, skill, know-how or processes was not satisfied. On that basis, the addition treating the receipts as taxable fees for technical services was deleted.</description>
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