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2008 (7) TMI 456 - AT - Income TaxExtract: ....... we are of the view that the Departmental authorities went wrong in their conclusion that the amount remitted by the assessee to PBAT in Thailand was royalty within the meaning of s. 9(1)(vi) of the IT Act and art. 12(3) of the double tax treaty with Thailand. We set aside their orders and allow the appeal of the assessee with no order as to costs.
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