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    <title>2011 (5) TMI 586 - ITAT, MUMBAI</title>
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    <description>The appeal was allowed in favor of the assessee regarding the taxability of the amount received from Standard Chartered Bank (SCB) as royalty. The Tribunal found that the payment did not qualify as royalty under the Double Taxation Avoidance Agreement (DTAA) and Income-tax Act, as there was no positive use or employment of equipment by the recipient. The decision was based on the lack of control or access to computer hardware by the assessee, leading to the conclusion that the payment was not considered royalty.</description>
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      <title>2011 (5) TMI 586 - ITAT, MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=210105</link>
      <description>The appeal was allowed in favor of the assessee regarding the taxability of the amount received from Standard Chartered Bank (SCB) as royalty. The Tribunal found that the payment did not qualify as royalty under the Double Taxation Avoidance Agreement (DTAA) and Income-tax Act, as there was no positive use or employment of equipment by the recipient. The decision was based on the lack of control or access to computer hardware by the assessee, leading to the conclusion that the payment was not considered royalty.</description>
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      <pubDate>Fri, 27 May 2011 00:00:00 +0530</pubDate>
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