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2021 (8) TMI 1232

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....espondent : Sri.Pradeep Kumar, CIT-DR ORDER Per George George K, JM This appeal at the instance of the assessee is directed against final assessment order dated 21.10.2016, passed u/s 143(3) r.w.s. 144C(13) of the I.T.Act. The relevant assessment year is 2016-2017. 2. The solitary issue raised is whether sale of software was liable to be taxed as royalty. 3. Brief facts of the case are as fol....