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2009 (11) TMI 19 - AUTHORITY FOR ADVANCE RULINGSTax on Royalties - The DTAA has been amended by reducing the maximum rate of tax payable on royalty at 10% and the protocol was notified by the Central Govt. under Section 90 of the Income-Tax Act, 1961 on 19th July, 2006. The applicant contends that in view of the amendment, the tax liable to be paid on the gross amount should be @ 10% instead of 20% - held that - income by way of royalty accruing to the applicant is liable to be taxed in terms of Article 12 of the DTAA at a rate not exceeding 10% from the assessment year 2008-09 onwards.
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