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2002 (12) TMI 43 - HC - Income Tax"Whether, Tribunal was right in law in holding that no tax was to be deducted at source on payment made by the assessee to AVL-Gesselschaft Fur Verbrennungskraftmachlan M.B.H. Austria for the feasibility study of improving the performance of the existing diesel engine 265 DI as the payment represented fees for technical services and not royalty?" - In the circumstances, without going into the merits of the impugned order which is under section 195, since payment has already been made to the Austrian company, both the above appeals are dismissed as infructuous.
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