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2019 (10) TMI 1541 - HC - Income TaxIncome deemed to accrue or arise in India - ITAT held as not chargeable to tax under section 9(1)(vi) read with Article 12(3) of the DTAA between India and USA as royalty - HELD THAT:- The present appeal is directed against the order passed by the Income Tax Appellate Tribunal Delhi Bench (ITAT): “G‟, New Delhi in [2019 (4) TMI 1426 - ITAT DELHI] in respect of the assessment year 2012-13. The Tribunal has placed reliance on the decisions of this Court in M/s Asia Satellite Telecommunications Co. Ltd. [2011 (1) TMI 47 - DELHI HIGH COURT] and Director of International Taxation Vs. New Skies Satellite BV, [2016 (2) TMI 415 - DELHI HIGH COURT]. Since the issues raised by the Revenue are squarely covered by the aforesaid decisions of this Court, in our view, no question of law arises for our consideration.
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