2011 (7) TMI 522

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....the Income Tax Act, 1961 is the question raised in this appeal.   2. The assessment year involved herein is assessment year 2004-05.   3. In the assessment year in question, the assessee filed return of income and claimed refund of tax on the ground that the amount of royalty received by the assessee was covered under Article 7 of the Double Taxation Avoidance Agreement between India a....