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2016 (12) TMI 1598 - HC - Income TaxAmounts paid by the assessee to its licensors - whether sum amounted to royalty within the meaning of the expression under Section 9(1)(vi) and Article 12 of the Indo-Finland Double Taxation Avoidance Agreement (DTAA)? - Held that:- The Income Tax Appellate Tribunal (ITAT) followed the previous judgments of this Court including the judgment in DIT v. Infrasoft Ltd. [2013 (11) TMI 1382 - DELHI HIGH COURT] and also the judgment – DIT (International Taxation) vs. Nokia Networks (2012 (9) TMI 409 - DELHI HIGH COURT ). The later decision had an occasion to interpret the same provision in the context of the very same treaty. Since the ITAT has followed the previous binding judgments of this Court, the present appeals do not raise a substantial question of law.
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