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2016 (10) TMI 1218 - AT - Income TaxRoyalty - data processing cost paid by the assessee - TDS liability on data processing cost paid by the assessee to the head office - Existence of Permanent Establishment (PE) of the foreign bank - Scope of amendment to ection 9(2) - DTAA between India and Germany - Held that:- the impugned payment made by the Branch to the H.O. towards reimbursement of cost of data processing cannot be held to be covered within the scope of expression “royalty” - Decided in favor of assessee.
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