Transfer of Technology Fee Not Royalty or Technical Fee u/s 9(1)(vi) Due to Insufficient Evidence.

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....Additions u/s. 9(i)(vi) - transfer of technology fee as royalty or technical fee - In the absence of any findings from the Revenue that the Acqueon Technologies Ltd Inc. USA was paid over and above the purchase price, its treatment that the impugned transaction falls u/s. 9(1)(vi) is not valid - AT....