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2015 (11) TMI 1117 - AT - Income TaxTaxability of borrowed service charges and the applicability treaty benefits under India-US tax treaty - Held that:- The issue has been settled under the MAP proceedings arrived at settlement between Government to Government level and therefore, honouring the same, we hold that such a borrowed services is not part of fees for technical services/fees for included services and hence not taxable in India. - Decided in favour of assessee
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