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2013 (11) TMI 1368 - AT - Income TaxConsultancy charges – Tax to be deducted on payment – The assessee engaged M/s Stratum Resources as marketing agent for South East Asian countries - Held that:- The work of the foreign party is to identify the potential customer and file a report regarding the market strategy and developmental studies - Agreement is not for the marketing of product of the assessee in South East Asian countries - The impugned agreement has to be viewed by substance of the transaction and not by the nomenclature - The substance of the agreement is for consulting the foreign party for marketing the product of the assessee in South East Asian countries. Therefore, it is only consultancy charges - The substance of the impugned agreement is only consultancy agreement – Decided against assessee.
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