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Case Law Details

Case Name : Wheels India Ltd. Vs. ACIT (ITAT Chennai)
Related Assessment Year : 2005- 06
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Chennai bench of the Income-tax Appellate Tribunal  in the case of Wheels India Ltd. Vs. ACIT I.T.A No. 1793/Mds/2006 (Chennai) held that payment made to US companies for ‘developing tooling’ and ‘validating new process for manufacture’ of wheels for commercial vehicle was ‘fees for included services’ as per Article 122 of the India-USA tax treaty.

Facts of the case – The taxpayer was engaged in the manufacture of

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