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2021 (7) TMI 1276 - AT - Income TaxTDS u/s 195 - Royalty - Treatment to receipts of assessee’s on account of sale of software to the Indian customers, as royalty - HELD THAT:- As relying on ENGINEERING ANALYSIS CENTRE OF EXCELLENCE PRIVATE LIMITED [2021 (3) TMI 138 - SUPREME COURT] , we are of the view that Ld.CIT(A) erred in treating the receipts from sale of software with the support services as royalty.
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