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2021 (4) TMI 1269 - KARNATAKA HIGH COURTTDS u/s 195 - disallowance made under the provisions of Section 40[a][i] - payments made by the appellant company to non-residents are in the nature of Royalty without deducting TDS - HELD THAT:- issue involved in this appeal has been put to rest in view of the decision rendered in ENGINEERING ANALYSISCENTRE OF EXCELLENCE PRIVATE LIMITED [2021 (3) TMI 138 - SUPREME COURT] and the issue involved in this appeal has been answered against the Revenue and in favour of the assessee.
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