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2011 (9) TMI 208 - AT - Income TaxData processing charges - Amount payable outside India - withholding tax - Nature of payment - Royalties or Fees for Technical Services - Held that:- payments made by the assessee to SPL is not royalty within the meaning of Article 12(3)(b) of the treaty. As the business profits are not taxable by virtue of DTAA - Decided in favor of assessee.
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