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2019 (8) TMI 1755 - HC - Income TaxRoyalty receipt - Income taxable in India or not - existence of PE in India - Income taxable in India or not - existence of PE in India - 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]. Decided against the Revenue.
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