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It is therefore maybe not an effective Royalty money as outlined under Article a dozen of your own India-United states of america DTAA Article a dozen of one’s Asia-U . s . DTAA S. 9: Money – Considered so you’re able to accrue otherwise arise in the Asia (Royalties/costs to own technical attributes – Remittance) – payment built to Us established organization toward rates compensation about what activities got equal to fool around with and not paid off amount to royalty, levy of interest u/s. 201(1A) are unjustified. The brand new AO introduced buy you/s. 201(1) and you may kept one to remittance from assessee so you’re able to GTRC was absolutely nothing however, royalty depending on specifications off s.9 (1)(vi) plus regards to blog post twelve away from DTAA ranging f...

Reading Albanian names and you can nicknames is a great solution to discover a whole lot more regarding your community Names had been at the mercy of historical adjustment, therefore the hottest brands are constantly moving forward. As an example, when you look at the 2021, the most famous very first-label getting a child boy are Noel once the well-known first-term for a female had Amelia. In which Create very first Labels During the Albania Originate? The brand new twentieth millennium produced grand modifications in order to Albania, and therefore the naming degree.