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    <title>2016 (4) TMI 123 - ITAT BANGALORE</title>
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    <description>The Tribunal ruled in favor of the assessee-company, determining that the payments to Shri Mohan Raju were not considered royalty as they were for acquiring controlling interest in new business initiatives and did not involve the transfer of intellectual property rights. Consequently, the provisions of section 194J for tax deduction at source did not apply. The Tribunal also clarified that any demand should be recovered from the payee if the assessment was already completed, aligning with the principle established in Hindustan Coca Cola Beverages (P.) Ltd. v. CIT.</description>
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      <description>The Tribunal ruled in favor of the assessee-company, determining that the payments to Shri Mohan Raju were not considered royalty as they were for acquiring controlling interest in new business initiatives and did not involve the transfer of intellectual property rights. Consequently, the provisions of section 194J for tax deduction at source did not apply. The Tribunal also clarified that any demand should be recovered from the payee if the assessment was already completed, aligning with the principle established in Hindustan Coca Cola Beverages (P.) Ltd. v. CIT.</description>
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