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2015 (10) TMI 2513 - ITAT DELHI

2015 (10) TMI 2513 - ITAT DELHI - TMI - Sale of software and maintenance services – Payments to be taxable as Royalty u/s 9(1)(vi) of the Act – Article 12 of DTAA between India and US - Held that:- Even though there is amendment to the Finance Act, 2012, there is no change in the DTAA between India and USA and the same was not refuted by the DR. Therefore, in light of assessee’s own case for the A.Y 2008-09 [2014 (4) TMI 369 - ITAT DELHI ]appeals are covered in assessee’s favour wherein held wha .....

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not taxable - Decided in favour of Assessee. - I.T.A .No. 6273/Del/2012, I.T.A .No. 690/Del/2014 - Dated:- 23-10-2015 - R. S. Syal (Accountant Member) And Suchitra Kamble (Judicial Member) For the Appellant : Amit Arora (CA), Suraj Nangia (CA) For the Respondent : Anuj Arora, CIT DR ORDER Suchitra Kamble (Judicial Member) 1. During the course of the hearing, the assessee s counsel submitted that the matter is covered by assessee s own case for the A.Y 2008-09 in favour of the assessee being ITA .....

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