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I.T.C. Limited Versus A.D.I.T.(I.T.) -2 (1) , Kolkata - 2017 (3) TMI 142 - ITAT KOLKATA

Tds U/S 195 - Grant of license - P.E. in India - whether the sums paid by the Appellant to NPL is in the nature of Royalty chargeable to tax in India has to be decided - Whether the definition of Royalty as provided under the Income Tax Act is to be taken or that which has been provided in the DTAA between India and Singapore? - Held that - We have to clarify that Explanation-4 to Sec.9(1)(vi) of the Act was inserted by the Finance Act, 2012 w.r.e.f 1-6-1976 which enlarges the definition of Roya....... + More

 

 

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