Assessee's Lack of Evidence Leads to Entire Payment Being Treated as Royalty; Decision Upheld with No Errors Found.

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....Where the assessee has failed to produce the relevant information, details and record to support its case and which is also necessary to segregate such part of the payment which may not be falling under the purview of royalty, we do not find any error or illegality in the impugned orders of authorities below in treating the entire consideration received by the assessee as royalty - AT....