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    <title>2023 (2) TMI 364 - ITAT DELHI</title>
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    <description>Satellite transmission receipts were held not to constitute royalty under the Income-tax Act, 1961 or the India-USA DTAA, because the issue had already been decided in the assessee&#039;s favour in earlier years and affirmed by the jurisdictional High Court; the same treatment was therefore followed for the year in question. TDS credit was also directed to be allowed in accordance with law, subject to the assessee furnishing supporting evidence and verification. On that basis, the principal addition was deleted and the appeal was allowed, with the credit issue restored only for lawful examination.</description>
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      <description>Satellite transmission receipts were held not to constitute royalty under the Income-tax Act, 1961 or the India-USA DTAA, because the issue had already been decided in the assessee&#039;s favour in earlier years and affirmed by the jurisdictional High Court; the same treatment was therefore followed for the year in question. TDS credit was also directed to be allowed in accordance with law, subject to the assessee furnishing supporting evidence and verification. On that basis, the principal addition was deleted and the appeal was allowed, with the credit issue restored only for lawful examination.</description>
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