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1 - 2 of 2 (0.34 seconds)H.J. Heinz Company, Usa, Mumbai vs Acit, New Delhi on 23 August, 2019
19. On a careful reading of the said judgment, we find that the
decision of the Coordinate Bench is distinguishable on facts as
the services rendered in case of that assessee is in relation to
manufacture of products. Whereas, in the facts of the present
appeal, services rendered are not in relation to any manufacturing
activity. In this view of the matter, the receipts cannot be treated
as FIS under Article 12(4)(b) of the tax treaty. The Assessing
Officer is directed to delete the addition.
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