TMI Blog2022 (7) TMI 1558X X X X Extracts X X X X X X X X Extracts X X X X ..... y (ICT) service charges to be taxed as Fees for Technical Services under Article 12 of the India-Netherlands DTAA - HELD THAT:- During the hearing of the stay petition, it was accepted and it was consented by both the parties that the issues involved in the present appeal are squarely covered by the order of the Tribunal in Assessee s own case for Assessment Year 2017-18 [ 2022 (2) TMI 1292 - ITAT ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... eal are squarely covered by the order of the Tribunal in Assessee s own case in ITA No. 139/Del/2021 for Assessment Year 2017-18 allowing the appeal of the Assessee. Since, the matter is squarely covered by the ratio laid down in the order of the Tribunal in assessee s own case, the same ratio is being followed for the years before us. 3. In the result, the appeals of the Assessee are allowed. 4. ..... X X X X Extracts X X X X X X X X Extracts X X X X
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