2022 (11) TMI 631

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....ustice Manmohan And Hon'ble Ms. Justice Manmeet Pritam Singh Arora For the Appellant : Mr. Ruchir Bhatia, Senior Standing Counsel for Revenue. For the Respondent : Mr. Divyanshu Agrawal, Ms. Ritika Chawla & Mr. Vaibhav Niti, Advocates. JUDGMENT MANMOHAN, J (Oral): CM APPL. 47203/2022 (for exemption) in ITA 435/2022 Exemption allowed, subject to all just exceptions. ....

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.... 'Fee for included services' as defined under Articles 12(4) (a) of the Indo- US DTAA. 3. He states that the ITAT has allowed the appeals of the Assessees following the judgement of this Court in Director of Income Tax v. Sheraton International Inc (2009) 178 taxman 84 (Del). He, however, states that the said decision of this Court has not been accepted by the Revenue and an appeal has been....