Reference in Article 13(3)(c) of Indo-Canada DTAA is to "any copyright" and it is not a reference to "any right" for purpose of terming a payment as `royalty’

CASE LAWS DETAILS DECIDED BY: HIGH COURT OF NEW DELHI, IN THE CASE OF: Director of Income Tax Vs Sahara India Financial Corporation Ltd., Appeal No: ITA No. 1064/2007, DECIDED ON: February 19, 2010 RELEVANT PARAGRAPH BADAR DURREZ AHMED, J (ORAL) 1. This appeal preferred by the revenue is directed against the Income Tax Appellate Tribunal .s order dated 28.07.2006 passed in ITA No. 491/Del/2000 and relates to the assessment year 1998- 1999. 2. The revenue is aggrieved by the finding of the Tribunal that the payment of US $ 9,24,500/- by the assessee, as per the agreement dated...