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Royalty u/s 9(1)(vi) read with DTAA - It is fallacious to assume that any change made to domestic law to rectify a situation of mistaken interpretation can spontaneously further their case in an international treaty. Therefore, mere amendment to Section 9(1)(vi) cannot result in a change - HC

Income Tax - Royalty u/s 9(1)(vi) read with DTAA - It is fallacious to assume that any change made to domestic law to re .....

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