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2014 (1) TMI 1281 - AT - Income TaxTaxability of Royalty u/s 9(1)(vi) of the Act and Article 12 of Ireland DTAA - Payment received from customers – Held that:- The decision in CIT (IT) v. Wipro Ltd. [2011 (10) TMI 473 - KARNATAKA HIGH COURT] followed - a customer of the present assessee made payment without deduction of tax at source u/s 195 of the Act - the payments made for online use of database was for licence to use said database and hence the consideration was royalty, liable for deduction of tax at source u/s 195 of the Act – Decided against Assessee.
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