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2024 (4) TMI 591 - AT - Income TaxRoyalty receipts - income deemed to accrue or arise in India - assessee had sold software licenses to its associated enterprises and to other Indian customers - HELD THAT:- As decided in assessee own case [2021 (9) TMI 1542 - KARNATAKA HIGH COURT] relying on the case of Engineering Analysis Centre of Excellence Pvt. Ltd. (2021 (3) TMI 138 - SUPREME COURT] sale proceeds received by the assessee on sale of software licenses cannot be categorized as "Royalty" within the meaning of provisions of DTAA. Accordingly, we set aside the order passed by Ld. CIT(A) on this issue and direct the A.O. to delete the addition made as "royalty" income - Decided in favour of assessee.
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