2013 (4) TMI 641

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....consideration is as under: Whether on the facts and circumstances of the case and in law the Tribunal was correct in holding that the assessee is the beneficial owner of the royalty income received from the Universal Music India Private Ltd. and therefore entitled for the tax rate of 10% as per the DTAA? 2. The respondent assessee claimed benefit of Article 12 of the Double Tax Avoidance Agr....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ceived in respect of musical track given to M/s. Universal Music Pvt. Ltd. Besides, reliance was placed by the Tribunal upon the CBDT Circular No.789 dated 13/4/2000 that certificate from revenue authorities is sufficient evidence of beneficial ownership. On these findings of fact the Tribunal upheld the order of CIT(A) and held that the respondent assessee is entitled to benefit of Article 12 of ....