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1993 (8) TMI 97 - AT - Income TaxExtract: .......ner. The question of accrual of the income in India would, therefore, be irrelevant to the issue of taxation of technical services fee received by the assessee. We therefore, do not find any merit in this particular ground of the assessee also and reject the same. 10. In the result, the appeals filed by the assessee for all the years are dismissed.
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