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2013 (1) TMI 1053 - BOMBAY HIGH COURTExtract: ....... of the double Taxation Avoidance Agreement between India and Germany (DTAA)? b) Whether the Tribunal's decision should be vacated in view of the specific Explanation 4 to section 9(1)(vi) as amended by Finance Act, 2012 clarifying the definition of royalty in case of rights in relation to software with retrospective effect from 1st June, 1976?
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