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2022 (6) TMI 882 - AT - Income TaxTDS u/s 195 - Receipt of sale of software licenses as ‘Royalty’ - Addition in accordance with the provisions of section 9(1)(vi) and Article 12 of the DTAA between India and Singapore - HELD THAT:- We are of the considered view that the impugned quarrel is now well settled by the decision in favour of the assessee and against the Revenue in the case of Engineering Analysis Center of Excellence Pvt [2021 (3) TMI 138 - SUPREME COURT] - we direct the Assessing Officer to delete the impugned addition. - Decided in favour of assessee.
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