Royalty income from franchisee hotels - there is no agreement in terms of which the assessee was paid...

Royalty income from franchisee hotels - there is no agreement in terms of which the assessee was paid royalty is legally and factually correct, and therefore, the beneficial rate of tax will not apply. - A.O. has rightly charged the tax rate of 15% as given in the DTAA instead of 11.33% - AT .....

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