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    <description>Consideration paid to non-resident licensors for technology, know-how and technical information was examined on the distinction between royalty, transfer of copyright and supply of technical material under section 9(1)(vi) and article 12 of the DTAA, but the Tribunal did not decide the merits and remitted the issue to the first appellate authority for fresh consideration. The connected claim for interest on refund under section 244A, raised by a deductor, was also restored for reconsideration because it was linked to the main controversy. The connected appeals and cross-objections were disposed of for statistical purposes.</description>
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