Commissioner Of Income Tax "," Anr. vs Samsung Electronics Co. Ltd. "," Ors.
Whether on facts and circumstances of the case, the Tribunal was justified in holding that the amount(s) paid by the appellant(s) to the foreign software suppliers was not 'royalty' and that the same did not give rise to any 'income' taxable in India and, therefore, the appellant(s) was not liable to deduct any tax at source? --- Held: Yes, in favour of the assessee.
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