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2019 (6) TMI 1689 - AT - Income TaxIncome deemed to accrue or arise in India - Royalty receipt - Appellant liability to be assessed to tax in India - India-USA Double Taxation Avoidance Agreement - HELD THAT:- Identical issues were considered by the co-ordinate bench [2019 (4) TMI 1426 - ITAT DELHI] wherein held the issue in favour of the assessee and answer the issue stating that the income received by the assessee cannot be taxed as royalty in India. Needless to say, that the question of interest is only consequential in nature. Revenue went in further appeal before the Hon'ble High Court of Delhi. The Hon'ble High Court [2019 (4) TMI 2092 - DELHI HIGH COURT] relying on the judgment in the case of GE Packaged Power Inc [2015 (1) TMI 1168 - DELHI HIGH COURT] confirmed the order of the Tribunal - we allow the grounds raised by the assessee.
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