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2011 (5) TMI 351 - AAR - Income TaxDTAA with UK - Royalty or Fees for technical services - No permanent establishment - data processing services agreement - TDS u/s 195 - All the services do not speak of rendering any managerial, technical or consultancy services. In the written submission the applicant has said that these are in the nature of routine data entry, application sorting, document handling and data capturing services and do not involve the usage of any sophisticated technology. - Held that:- these services can not be held as technical, managerial or consultancy services - the consideration received for such services is not taxable.
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