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2020 (7) TMI 829 - AT - Income TaxIncome deemed to accrue or arise in India - addition on account of alleged royalty taxable u/s 9 (l)(vi) of the Income Tax Act, 1961 read with article 12(3) of India Switzerland Double Taxation Avoidance Agreement - HELD THAT:- As decided in assessee's own case 2013-14, [2020 (11) TMI 466 - ITAT MUMBAI] we uphold the plea of the assessee and delete the impugned addition. No other issues were pressed before us. In any event, the other points raised in the appeal were in the nature of consequential levies. Decided in favour of assessee.
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