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2021 (12) TMI 1418 - AT - Income TaxIncome deemed to accrue or arise in India - receipts of the appellant are in the nature of "Royalties" within the ambit of Explanation 2 to section 9(i)(vi) and Article 12(3) of the India-USA Double Taxation Avoidance Agreement ("DTAA") - HELD THAT:- We find force in the contention of the ld. counsel for the assessee. A similar quarrel was considered and decided by this Tribunal [2021 (10) TMI 1389 - ITAT DELHI] we direct the Assessing Officer to treat the income of the assessee as not liable to tax in India. Appeal of assessee allowed.
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