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    <title>2017 (4) TMI 1461 - ITAT MUMBAI</title>
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    <description>Payments received from Indian customers were treated as royalty rather than business income because the assessee was found to provide qualitative reports beyond compiling public-domain information, and the Tribunal followed its earlier adverse view in the absence of any contrary ruling from the jurisdictional High Court. By contrast, interest under section 234B was not sustainable against the non-resident assessee because the relevant income was subject to tax deduction at source in the payer&#039;s hands, so no advance tax liability arose on that income. The result was partial relief to the assessee, with the royalty characterization sustained and the interest levy deleted.</description>
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    <pubDate>Wed, 12 Apr 2017 00:00:00 +0530</pubDate>
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      <title>2017 (4) TMI 1461 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=282613</link>
      <description>Payments received from Indian customers were treated as royalty rather than business income because the assessee was found to provide qualitative reports beyond compiling public-domain information, and the Tribunal followed its earlier adverse view in the absence of any contrary ruling from the jurisdictional High Court. By contrast, interest under section 234B was not sustainable against the non-resident assessee because the relevant income was subject to tax deduction at source in the payer&#039;s hands, so no advance tax liability arose on that income. The result was partial relief to the assessee, with the royalty characterization sustained and the interest levy deleted.</description>
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      <pubDate>Wed, 12 Apr 2017 00:00:00 +0530</pubDate>
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