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2018 (4) TMI 1884 - HC - Income TaxRoyalty receipt - customer royalty programmes provided by the assessee to its client and customers - fees for technical services amounted to royalty under Article 12 of India US DTAA - HELD THAT - This question is covered by the ruling of this Court in assessee s case i.e. Director of Income Tax Vs. Sheraton International Inc. 2009 (1) TMI 27 - DELHI HIGH COURT .
The Delhi High Court dismissed the appeal regarding customer royalty programs, stating that no question of law arises as it is covered by a previous ruling. The case involved whether the programs amounted to fees for technical services or royalty under the India-US DTAA.
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