2025 (2) TMI 719

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..... Payment for certification of Diamonds - as per HC [2023 (8) TMI 296 - GUJARAT HIGH COURT] based on factual appreciation especially the condition in the customer service agreement, the bank invoice and the Bank remittance advice a finding of fact has been arrived at that the assessee's case was protected under the India-USA DTAA and that mere rendering of services cannot be roped into FTS unless t .....

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..... rs. Rajeshwari Shankar, Adv. Ms. Munisha Anand, Adv. ORDER UPON hearing the counsel the Court made the following. 1. Delay condoned. 2. Having heard the learned Additional Solicitor General appearing for the petitioner and having gone through the materials on record, it appears that the tax effect of the subject matter of the Special Leave Petition is falling below the threshold contained in t .....

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