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2021 (11) TMI 217 - AT - Income TaxIncome accrued in India - Royalty receipts - receipts from Indian customers - receipts from CAS division as well as from PUBS division - India-USA DTAA - HELD THAT:- As relying in assessee's own case [2019 (4) TMI 1818 - ITAT MUMBAI] we would hold that receipts from CAS division as well as from PUBS division could not be held to be royalty and hence, not taxable in the hands of the assessee. - Decided in favour of assessee.
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