TMI Blog2022 (9) TMI 1572X X X X Extracts X X X X X X X X Extracts X X X X ..... - Income Tax - Accrual of income in India or not - Fee received by the assessee under the Centralized Services Agreement - whether FIS either under Article 12(4)(a) or 12(4)(b) of the India US Tax Treaty - HELD THAT:- We find force in the contention of the Counsel because identical grievance have been heard and decided by this Tribunal [ 2022 (7) TMI 781 - ITAT DELHI] in favour of the assessee a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nd are disposed of by this common order for the sake of convenience and brevity. 3. Since identical grounds have been taken in the captioned appeals for the sake of our convenience. We are taking grounds of ITA No.394/Del/2022 pertaining to A.Y. 2016-17:- 4. At the very outset the Counsel for the assessee stated that identical grievance have been considered by this Tribunal in a bunch of appeals b ..... X X X X Extracts X X X X X X X X Extracts X X X X
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