2024 (2) TMI 1050

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..... ndia as Royalty under Section 9(1)(vi) read with Article 12 of the Indo US DTAA - HELD THAT:- The issue raised by the Revenue in the present special leave petition is covered against them in the case of Engineering Analysis Centre of Excellence Private Limited [ 2021 (3) TMI 138 - SUPREME COURT] wherein held that the payment received for providing access to computer software to its member firms .....

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..... TICE DIPANKAR DATTA For the Petitioner : Mr. N Venkatraman, A.S.G. Mr. Arijit Prasad, Sr. Adv. Mr. Raj Bahadur Yadav, AOR Mr. Prasenjeet Mohapatra, Adv. Mr. Navanjay Mahapatra, Adv. Dr. Nishesh Sharma, Adv. Mr. Deepak Kumar, Adv For the Respondent : Mr. Nageswar Rao, Adv. Mr. Parth, AOR Ms. Viyushti Rawat, Adv ORDER UPON hearing the counsel, the Court made the following. Dela .....

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