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2024 (2) TMI 640 - AT - Income TaxAccrual of income in India - receipts on account of logistic support services, reimbursement of global account management charges and lease line charges - Fee for Technical Services/Fee for Included Services ("FTS'/ "FIS") as per the provisions of section 9(1)(vii) and Article 12 of the India-USA DTAA - HELD THAT:- As decided in assessee own case [2023 (5) TMI 1296 - ITAT DELHI] these issues has been consistently decided in favour of the assessee in all these years, while holding that the amount received are not in the nature of FTS/FIS either under the Act or under treaty provisions. Accordingly, the addition was deleted. Decided in favour of assessee.
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