2018 (3) TMI 1991

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..... the fact that the alternative submission made by the respondent before the authorities was that the payment made to its overseas branch at Singapore in respect of the data processing fees was really in the nature of reimbursement. The impugned order of the Tribunal has on facts found that the payment made by the respondent assessee to it overseas branch at Singapore was in the nature of reimburse .....

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..... ellate Tribunal (the Tribunal). The impugned order is in respect of Assessment Year 200607. 2 The Revenue has urged only the following reframed question of law for our consideration : i) Whether on the facts and circumstances of the case, the Tribunal was justified in holding that the payment of data processing fees paid by the assessee to its overseas branch at Singapore is in the nature o .....

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