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Royalties/Fees for technical services – Managerial service

February 28, 2024

Where assessee, Singapore based company, provided disaster recovery playout services in India, since playout service was integral feature of broadcasting and/or transmission of channels and ,thus, did not involve decision making and that service was essentially to ensure consistency in broadcasting of channels and, thus, uninterrupted availability thereof ,receipts from same would not be in nature of FTS – Principal Commissioner of Income-tax, (IT-2) v. Planetcast International (P.) – [2024] 159 taxmann.com 714 (Delhi)

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