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    <title>2016 (5) TMI 156 - ITAT MUMBAI</title>
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    <description>The Tribunal ruled in favor of the assessee, determining that income from the sale of shrink-wrap software was not taxable as royalty in India. The payments were classified as business income, and since the assessee lacked a Permanent Establishment in India, the income was not subject to taxation in India. The Tribunal directed the Assessing Officer to remove the disputed addition of Rs. 19,20,14,000. The appeal was allowed, and the judgment was delivered on 31st March 2016.</description>
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      <link>https://www.taxtmi.com/caselaws?id=327175</link>
      <description>The Tribunal ruled in favor of the assessee, determining that income from the sale of shrink-wrap software was not taxable as royalty in India. The payments were classified as business income, and since the assessee lacked a Permanent Establishment in India, the income was not subject to taxation in India. The Tribunal directed the Assessing Officer to remove the disputed addition of Rs. 19,20,14,000. The appeal was allowed, and the judgment was delivered on 31st March 2016.</description>
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