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Issues: Whether the provisions of Section 9(1)(vi) of the Income-tax Act, 1961, as amended by the Finance Act, 2012, applied to consideration for use of standard facilities so as to constitute royalty.
Analysis: The controversy was stated to be squarely covered by the decision of the Supreme Court in Engineering Analysis Centre of Excellence Private Limited, which held that mere use of standard facilities did not amount to royalty within the meaning of Section 9(1)(vi).
Conclusion: The question was answered against the Revenue and in favour of the assessee.
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