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2004 (4) TMI 70 - AAR - Income TaxApplicant entered into two separate agreements in respect of IP Licence and Fee Agreement and Trademark Licence and Fee Agreement with the foreign company for consideration (royalty) specified therein payable by the applicant to the said company - "fees for technical services" which foreign company received from applicant under the management services agreement, would be subject to tax in its hands in India as per provisions of Income-tax Act, 1961which include cash or receipt basis
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