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2021 (11) TMI 880 - AT - Income TaxIncome accrued in India - treating the receipts of assessee's on account of sale of software to the Indian customers, as royalty - DTAA between India and Netherlands - HELD THAT:- As relying on ENGINEERING ANALYSIS CENTRE OF EXCELLENCE PRIVATE LIMITED VERSUS THE COMMISSIONER OF INCOME TAX & ANR. [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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