IT/ILT : Where during assessment under section 143(3), receipts by assessee-US company was treated as royalty and taxed on gross basis at rate of 15 per cent, but Assessing Officer initiated reassessment contending that, since assessee had a PE in India, said receipt was to be attributed to Indian PE and said amount was to be taxed at 20 per cent, since Assessing Officer had earlier examined entire issue of royalty and its taxability in its entirety and all relevant facts were fully and truly di
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