2021 (4) TMI 1269

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..... ny to non-residents are in the nature of Royalty without deducting TDS - HELD THAT:- issue involved in this appeal has been put to rest in view of the decision rendered in ENGINEERING ANALYSISCENTRE OF EXCELLENCE PRIVATE LIMITED [ 2021 (3) TMI 138 - SUPREME COURT] and the issue involved in this appeal has been answered against the Revenue and in favour of the assessee.
THE HON'BLE MR. JUSTICE S .....

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..... rcumstances ofthe case?" 3. Heard the learned Counsel for the parties at length. 4. Learned Counsel for the assessee submitted that the issue involved in this appeal has been put to rest in view of the decision rendered by the Supreme Court in Civil Appeal Nos.8733-8734/2018 between ENGINEERING ANALYSISCENTRE OF EXCELLENCE PRIVATE LIMITED VS THE COMMISSIONER OF INCOME-TAX & ANOTHER vide ord .....

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