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2022 (6) TMI 1382 - AT - Income TaxIncome deemed to accrue or arise in India - income from Information Technology Support Services and income from Management Services - royalty or Fees for Technical Services (FTS) - HELD THAT:- As relying on assessee's own case [2019 (7) TMI 402 - ITAT PUNE] Extant payment received by the assessee can neither be considered as royalty u/s 9(1)(vi) of the Act nor as fees for technical services and therefore, the same cannot be included in the total income of the assessee. Grounds No. 1 and 2 of the assessee's appeal are allowed.
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