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2014 (1) TMI 1877
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....<br>Income Tax<br>Dr. O.K.Narayanan, Vice-President And Shri Vikas Awasthy, Judicial Member Assessee by : Shri Sriram Seshadri, CA Revenue by : Shri T.N. Betgeri, IRS, JCIT ORDER Dr.O.K.Narayanan, This is a bunch of five appeals. Four appeals are filed by the assessee for the assessment years 2003-04, 2004-05, 2005-06 and 2006-07. The fifth appeal is filed by the Reven....
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.... not taxable in India under Section 9(1)(vi). 5. In fact, the assessing authority has treated the payments in the nature of royalty as against payments towards purchase consideration, as argued by the assessee. 6. This issue has already been decided by the ITAT, Chennai B-Bench in the case of Dassault Systems Simulia P. Ltd. (formerly known as Abacus Engineering Pvt. Ltd.) through the....