Gross Amount’ of royalty under Indo-USA DTAA includes tax withheld

 ITAT DELHI Pizza Hut International LLC v. Deputy Director of Income-tax, Circle 2(1), International Taxation IT Appeal NOS. 1600, 1601 & 1656 (DELHI) OF 2011 [ASSESSMENT YEARS 2003-04 & 2004-05] JUNE 8, 2012 ORDER K.G. Bansal, Accountant Member These three appeals for two different years, consisting of one appeal of the assessee and two appeals of the revenue, were argued in a consolidated manner by the Ld. Counsel for the assessee and the Ld. Sr. DR. Therefore, we find it convenient to pass a consolidated order. 1.1 The assessee has taken up two grounds in its appe...