Allowing the appeal the Court held that since the High Court has not answered the question on merits the matter remanded to the High Court . Followed GE India Technology Centre (P) Ltd v. CIT ( 2010) 327 ITR 456 (SC)
Intel Technology India (P) Ltd v .CIT (IT) ( 2020) 121 taxmann.com 130 (SC)
S. 9(1)(vi) : Income deemed to accrue or arise in India – Royalty – High Court has not decided on merit – Matter remanded- OECD Model Convention . [ Art, 12 ]