Trademark Licensing Payments Classified as Royalties u/s 9(1)(vi) and India-Turkey Tax Treaty Article 12(3.

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....Income deemed to accrue or arise in India - the consideration received by the assessee for permitting the right to use of brand name/trademark under TLA is nothing else but in the nature of royalties as defined under section 9(1)(vi) read with Article 12(3) of India – Turkey tax treaty. Therefore, we concur with the view expressed by learned DRP. - AT....