https://www.taxtmi.com/caselaws?id=306177 The court ruled in favor of the assessee, determining that the payments received were not considered royalty under Section 9(1)(vi) of the Income Tax Act, 1961, and Article 12(3) of the Indo US Double Taxation Avoidance Agreement. The court emphasized the need for consistent interpretation in international taxation matters, affirming previous judgments' applicability to the case. The court dismissed the Revenue's arguments, finding no substantial question of law and supporting the taxability of the disputed amounts based on prior decisions. Consequently, the appeals were dismissed. en-us Wed, 10 Apr 2019 00:00:00 +0530 Sun, 15 Jan 2023 14:51:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=306177 The court ruled in favor of the assessee, determining that the payments received were not considered royalty under Section 9(1)(vi) of the Income Tax Act, 1961, and Article 12(3) of the Indo US Double Taxation Avoidance Agreement. The court emphasized the need for consistent interpretation in international taxation matters, affirming previous judgments' applicability to the case. The court dismissed the Revenue's arguments, finding no substantial question of law and supporting the taxability of the disputed amounts based on prior decisions. Consequently, the appeals were dismissed. Case-Laws Income Tax Wed, 10 Apr 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=306177