2021 (3) TMI 1215

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.... Alok Aradhe And Hon'ble Mr. Justice Ashok S. Kinagi For the Appellant : Suryanarayana T., Advocate. For the Respondents : Mr. Dilip Kumar, Advocate for Mr. K.V. Aravind, Advocate. JUDGMENT T. Suryanarayana, learned counsel for the assessee. Mr. Dilip Kumar, learned counsel for the Revenue. 2. This appeal under Section 260-A of the Income Tax Act, 1961, has been filed by the Rev....

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....lant was 'royalty' as defined under Explanation 2 to Section 9(1)(vi) of the Income Tax Act, 1961, and under the applicable DTAAs, giving rise to an income chargeable to tax in India and necessitating deduction of tax under Section 195 of the Act?" 3. When the matter was taken up today, learned counsel for the assessee submitted that the issue involved in this appeal has been put to res....