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2019 (10) TMI 1447 - AT - Income TaxIncome accrued in India - Centralized services fee received by the appellant for rendering various marketing, advertisement & other services to customers in India - whether taxable as “Fees for Technical Services” (FTS) in terms of Section 9 of the Income Tax Act, 1961 as well as Article 12 of the India US Double Taxation Avoidance Agreement (DTAA) - HELD THAT:- The said issue of taxability of these services as FTS u/s 9(1)(vii) was already decided by the Co-ordinate Bench of the ITA T for the assessment year 1995-96 in assessee's own case - Further, the order of the Tribunal has been affirmed by the Hon'ble High Court of Delhi [2009 (1) TMI 27 - DELHI HIGH COURT]. We hold that as on today, the issue has been covered by the judgment of Hon'ble Jurisdictional High Court, hence, no addition on this ground is called for. - Decided against revenue.
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