https://www.taxtmi.com/caselaws?id=306582 Receipts were held not taxable in India as royalty under section 9(1)(vi) and Article 12 of the India-USA DTAA because the issue was already covered by coordinate bench rulings in the assessee's own case and by the jurisdictional HC on similar facts. The Tribunal found no distinguishing feature shown by the Revenue and followed the settled position for earlier assessment years. On that basis, the assessee was entitled to treaty protection and the income was not liable to tax in India. en-us Fri, 20 May 2022 00:00:00 +0530 Thu, 09 Feb 2023 21:17:50 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=306582 Receipts were held not taxable in India as royalty under section 9(1)(vi) and Article 12 of the India-USA DTAA because the issue was already covered by coordinate bench rulings in the assessee's own case and by the jurisdictional HC on similar facts. The Tribunal found no distinguishing feature shown by the Revenue and followed the settled position for earlier assessment years. On that basis, the assessee was entitled to treaty protection and the income was not liable to tax in India. Case-Laws Income Tax Fri, 20 May 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=306582