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    <title>2020 (1) TMI 66 - ITAT MUMBAI</title>
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    <description>A defect in the copy of a draft assessment order forwarded under section 144C did not invalidate the final assessment order where the final order was duly signed and stamped and the omission in the assessee&#039;s copy was merely inadvertent. Subscription revenue from Indian customers was held to be royalty under the India-UK treaty and the Act following earlier co-ordinate bench rulings on identical facts. Once characterised as royalty, the alternative plea for limited taxation by reference to a permanent establishment did not survive. The assessee failed on both the procedural challenge and the substantive taxability challenge, and the appeal was dismissed.</description>
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      <description>A defect in the copy of a draft assessment order forwarded under section 144C did not invalidate the final assessment order where the final order was duly signed and stamped and the omission in the assessee&#039;s copy was merely inadvertent. Subscription revenue from Indian customers was held to be royalty under the India-UK treaty and the Act following earlier co-ordinate bench rulings on identical facts. Once characterised as royalty, the alternative plea for limited taxation by reference to a permanent establishment did not survive. The assessee failed on both the procedural challenge and the substantive taxability challenge, and the appeal was dismissed.</description>
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