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2012 (10) TMI 240 - ITAT MUMBAIRestoration of the matter - Purchase of Software from associate concern – The Assess contended that Microsoft software purchased by the associate concern on behalf of the assessee and payments made, when not for the transfer of right in the software is not a payment for royalty. Revenue contended as decided in case of [Samsung Electronics Co. Ltd. Versus Deputy Director of Income-tax (International Taxation), Circle-II(1) ]2012 (8) TMI 112 - ITAT BANGALORE payment made by the assessee to non-resident companies would amount to Royalty. Held that:- Issue restored back to COM(A) to examine the nature of software purchased by the assesse - Both the appeals are allowed for statistical purposes.
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