Bench: ALOK ARADHE,R. NATARAJ
TP)A No.1512/Bang/2010 dated 26.06.2015 even when assessing authority rightly held that payment for 3 purchase of software was in the nature of 'royalty' in terms of Explanation 2 to Section 9 (1)(vi) of the Act? (2) Whether on the facts and in the circumstances of the case, the Tribunal is right in setting aside disallowance made under Section