2018 (11) TMI 51

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..... nt to be in the nature of “royalty” as per provision of Section 9(1)(vi) of the Income Tax Act, 1961 as well as Article 12 of the India-Isreal Double Tax Avoidance Agreement and there by holding the Appellant as “Assessee in default” for not deducting TDS under Section 195 of the Act?” Issue notice to the respondent. Rule is made returnable by eight weeks. No ground for grant of anyinterim o .....

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..... estionsof law:- (i) Whether under the facts and the circumstances of the case and in law the learned ITAT has not erred inreversing the decision of the learned CIT (A) and holdingthe amount remitted by the appellant to be in the natureof royalty as per provision of Section 9(1)(vi) of the Income Tax Act, 1961 as well as Article 12 of the India-Isreal Double Tax Avoidance Agreement and there .....

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