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2010 (12) TMI 254 - AT - Income TaxDTAA - Royalty or Fees for Technical Services - The payment made to AVAYA INTERNATIONAL SALES LTD.,IRELAND("AISL") in respect of activation charges is a payment for buying a standard product/software - Definition of the term "Fees for Technical Services" given in section 9(1)(vii) of the Act as well as in Article 12 of DTAA between India and Ireland - the correct nature of the transaction is sale of the product and not the fees for technical services. - the Tribunal has decided the issue in favour of the assessee - Appeals of the Revenue are dismissed
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