respect of different parts of the land. Though the
conversion order was issued for the purpose of forming residential layout,
no such activity was formed ... that that
they are willing to pay the requisite charges and conversion fees for
renewal of the orders. Bringing our attention to the agreement
before
concluding, that the payments made towards export sales commission, were towards fee
for technical services."
ITA No.2406/Chny/2017 ... been located into Special Economic Zone (SEZ Zone) by reason of conversion of MEPZ from
export processing Zone status into SEZ Zone with effect from
deemed to have always included
transmission by satellite (including up-linking, amplification.
conversion for down-linking of any signal), cable, optic fibre ... section 9(1) of the Act. As far as Royalty and Fees
for Technical services are concerned, it is taxable irrespective of
the fact whether
considered as fee for included services.
According to the ld. DRP balance sum of ₹13,04,05,037/- could be
considered as fees for included ... rate of 15% considering it as fees for included services under Article 12
of the India and USA DTAA.
4. Now before us, ld. Authorised
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