NR beneficial Owner of Royalty income from Indian Company entitled to benefit of article 12 of DTAA between India and Netherlands

HIGH COURT OF BOMBAY Director of Income-tax (I.T.) versus Universal International Music B.V IT Appeal Nos. 1464 to 1466 of 2011 FEBRUARY 8, 2013 ORDER 1. In all these appeals the common question of law raised by the revenue for our consideration is as under: Whether on the facts and circumstances of the case and in law the Tribunal was correct in holding that the assessee is the beneficial owner of the royalty income received from the Universal Music India Private Ltd. and therefore entitled for the tax rate of 10% as per the DTAA? 2. The respondent assessee claimed benefit o...