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2022 (2) TMI 481 - AT - Income TaxIncome accrued in India - consideration earned by the Appellant from supply of CAS and Middleware products to the Indian customers - addition under royalties' as defined u/s. 9(1)(vi) of the Act and Article 12(3) of the India-Swiss Confederation Double Taxation Avoidance Agreement ('India-Swiss tax treaty') - HELD THAT:- Issue decided by the Hon'ble Tribunal in Appellant's own case [2020 (7) TMI 640 - ITAT DELHI] for the previous AY 2016-17 and even covered by the recent judgment of the Hon'ble Supreme Court in the case of Engineering Analysis Centre For Excellence Private Limited Vs. Commissioner Of Income Tax & Another [2021 (3) TMI 138 - SUPREME COURT] - Decided in favour of assessee.
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