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2006 (12) TMI 550 - HC - Income TaxExtract: ....... between the assessee and the Sumitomo Corporation. We have perused the various clauses of the agreement and the correspondence relied upon by the appellant. We are in agreement with the view taken by the ITAT that the arrangement was in the nature of an agency which would not attract the provisions of Section 80-O of the Income Tax Act. Dismissed.
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