2011 (2) TMI 77

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....92 of 2010 1. Although two issues are raised in this appeal, the only issue which is pressed is the disallowance of expenses incurred by the assessee under section 40(a)(i) of the Income-tax Act, 1961, on the ground that in the said expenses no tax at source was deducted. The Assessing Officer treated the payment made by the assessee to Microsoft as royalty and, therefore, came to the conclusio....