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Services liable to be taxed as FTS though same were rendered by separate agreement being part of main agreement

March 17, 2020[2020] 114 734 (Mumbai - Trib.)

INTERNATIONAL TAXATION : Where IT services rendered by assessee were subservient to royalty agreement and were ancillary and subsidiary to main royalty agreement entered into by both parties, assessee was not justified in holding that IT service was a separate and distinct agreement from main royalty agreement (Technology collaboration and technical assistance agreement) and, thus, it did not come under definition of FTS provided under India-Sweden tax treaty

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