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2017 (3) TMI 430 - ITAT MUMBAI
Royalties - payment to foreign companies towards purchase of certain software for its internal use in the business of the assessee - India-USA DTAA - P.E. in India - Held that:- As decided in assessee's own case [2016 (6) TMI 96 - ITAT MUMBAI ] the payments made for purchase of standardized software cannot be considered to be a royalty with the meaning of provisions of sec. 9(1)(vi) as well as India-USA DTAA. The orders passed by Ld CIT(A) holding the above view are upheld and other orders passed by Ld CIT(A) and that of the assessing officer are set aside. - Decided in favour of assessee