2021 (9) TMI 1473

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..... opyright i.e. the software and not the entire copyright itself, the payment cannot be treated as Royalty as per the Double Taxation Avoidance Agreement and Treaties? - HELD THAT:- As assessee submits that the substantial questions of law raised herein are squarely covered by the ruling of the Hon ble Apex Court in the case of Engineering Analysis Centre of Excellence Private Limited vs. The Commis .....

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