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2022 (7) TMI 1456 - DELHI HIGH COURTTaxability of foreign income in India - Royalty receipt - income earned from distributing of computer software in India - DTAA between India and USA - HELD THAT:- As considering the fact that the issue in dispute is squarely covered in favour of the assessee by the decision of Hon’ble Supreme Court in case of Engineering Analysis Centre of Excellence Pvt. Ltd. [2021 (3) TMI 138 - SUPREME COURT] amounts received from sale/supply of software licences and associated services are not taxable as royalty/FIS. Accordingly, he deleted the addition. Decided in favour of assessee.
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