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Bench: Sh. Saktijit Deydr. B. R. R. Kumar
business income of the assessee taxable in India if it has a PE in India. CONCLUSION 168. Given the definition of royalties contained in Article 12 of the DAAs mentioned in paragraph 41 of this judgment, it is clear that there is no obligation on the persons mentioned in section 195 of the Income-tax Act to deduct