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2015 (10) TMI 2810 - AT - Income TaxTax rate for royalty income - Determination of tax liability on income earned by way of Royalty earned by the assessee in India - India-USA DTAA - different rates for different payments - income arising out of agreements entered prior to 01.06.2005 were offered under the provisions of DTAA at the rate of 15% and income arising on account of agreements entered after 01.06.2005, were offered for taxas per the provisions of Section 115A of the Act, at 10% - HELD THAT:- We find that the issue raised by the Revenue in this appeal is squarely covered by the decision of the coordinate bench in IBM World Trade Corporation v. DDIT [2012 (5) TMI 58 - ITAT BANGALORE] CIT (A) has reproduced this decision in its entirely in his order. Nothing has been brought before us by the Revenue to take a different view. Especially so since the decision relied on by the CIT (A) was that of the assessee itself for an earlier year on the same set of facts.- Decided against revenue.
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