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2004 (1) TMI 16 - DELHI HIGH COURTRevenue after a lapse of six years issued notices requiring the assessee to show cause why the remittances made by it to Hewlett Packard (USA) in respect of salaries paid by HP (USA), on behalf of the assessee to four "foreign technicians"/expatriates, be not treated as "fee for technical services" and why the assessee should not be treated as an assessee-in-default for not deducting tax from the said payment under section 195 - Considering the documents placed on record and various other documents, the Tribunal has arrived at a conclusion that the remittances were by way of "salaries" and were not "fee for technical services" as claimed by the Revenue. - In our opinion, it cannot be said that the Tribunal has committed an error. - there is no substantial question of law - Hence, the revenue’s appeal is dismissed.
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