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TDS u/s 195 - payment made for transponder charges - royalty u/s 9 (1) (vi) - in Article 12 (3) of India Malaysia Treaty it is “ Secret Formula or process” is the term used and not “ process” , therefore meaning of term “ process” cannot be incorporated in the treaty, even otherwise, because then, the meaning of word “secret “ in treaty would become redundant. CIT (A) has also dealt with this argument of ld AO in his order and then order of ld CIT (A) worded identically in the issues decided by coordinate bench has been upheld. Therefore, this argument also deserves to be dismissed. - Decided against revenue. - AT
TDS u/s 195 - payment made for transponder charges - royalty u/s 9 (1) (vi) - in Article 12 (3) of India Malaysia Treaty it is “ Secret Formula or process” is the term used and not “ process” , therefore meaning of term “ process” cannot be incorporated in the treaty, even otherwise, because then, the meaning of word “secret “ in treaty would become redundant. CIT (A) has also dealt with this argument of ld AO in his order and then order of ld CIT (A) worded identically in the issues decided by coordinate bench has been upheld. Therefore, this argument also deserves to be dismissed. - Decided against revenue. - AT
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