ASSISTANT DIRECTOR OF INCOME TAX vs ANTWERP DIAMOND BANK NV
Whether reimbursement of data processing costs by an Indian branch to its foreign Head Office constitutes 'royalty' under section 9(1)(vi) of the Income Tax Act, 1961 and Article 12 of the Indo-Belgium DTAA, requiring tax deduction at source under section 195 and disallowance under section 40(a)(i) --- Held No.
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