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2010 (3) TMI 893 - AT - Income TaxBenefit of exemption under section 10(6A) income by way of royalty/fees for technical service assessee is a company incorporated in the Netherlands and is a tax resident of the Netherlands - assessee-company had entered into technology licence agreements - assessee filed a revised return under section 139(5) of the Act claiming a tax refund - Assessing Officer framed the assessment under section 143(3) on 29-3-2006, wherein he held that the assessee is not eligible for exemption under section 10(6A) of the Income-tax Act Held that:- Agreement made by the assessee-company with the Indian concern, namely M/s. Essar group is before the 1-6-2002 - agreement has been approved by the Central Government prior to that date - all the conditions laid down for exemption under section 10(6A) are fully satisfied exemption is available in favor of assessee
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