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2022 (5) TMI 1504 - AT - Income TaxIncome taxable in India - "Royalties" within the ambit of Explanation 2 to section 9(i)(vi) of the Income-tax Act, 1961 and Article 12(3) of the India-USA Double Taxation Avoidance Agreement (“DTAA”) - whether appellant being a resident of USA is covered by the beneficial provisions of DTAA between India and USA and accordingly, could not be taxed under the provisions of the Act? - HELD THAT:- The similar issues have been cropped up and the same have been considered and decided by this Tribunal in [2021 (10) TMI 1389 - ITAT DELHI] Thus respectfully following the ratio laid down above direct the AO to treat the income of the assessee as not liable to tax in India. Appeal of the assessee allowed.
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