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2020 (1) TMI 573 - AT - Income TaxRectification u/s 254 - reference to non-taxability of the amount as equipment royalty although the same is referred to in the extracted order of the earlier year - HELD THAT:- After the rectification, the relevant para No. 9 of the order shall now be read as under:- ”As the facts and circumstances during the year under consideration are same, respectfully following the order of the Tribunal in assessee‟s own case, we do not find any merit in the action of the lower authorities for treating the receipt as fees for technical services despite the concept of “make available‟ clause contained in article 13(4)(c) of the treaty or as equipment royalty. Accordingly, the A.O. is directed to delete the addition so made and Ground No. 5, 6 and 7 of the appeals are allowed. Except the above, there is no change in the Tribunal order.
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