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Royalty receipt - since the provisions of DTAA overrides the provisions of Income Tax Act and are more...

Royalty receipt - since the provisions of DTAA overrides the provisions of Income Tax Act and are more beneficial and the definition of ‘Royalty’ having not undergone any amendment in Tax Treaty, the assessee was not liable to be taxed on aforesaid receipts of Licensing software and also on sale of Hardware - AT .....

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