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ITAT directs AO to decide whether receipt for customized research/retail management services would royalty or FTS
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International Tax
ITAT directs AO to decide whether receipt for customized research/retail management services would royalty or FTS
Posted on
on
November 6, 2014
Tenet Tax Daily November 04 2014
By
tenettax-team
International Tax
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Assessee couldn’t challenge order of ITAT if it had applied amended provisions of MAT pursuant to directions of HC
ITAT allows benefit of second proviso to sec. 40(a)(ia) in case of payment to NR; Non-discrimination clause invoked
