2012 (6) TMI 203

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..... sub-clause [v] to Explanation 2 to Clause [vi] of section 9[1] of the Act – Held that:- yes, it is within the mischief of 'royalty' as defined under sub-clause [v] to Explanation 2 to Clause [vi] of section 9[1] of the Income Tax Act, 1961. Decided in favour of the revenue and against the assessee. Appeal is allowed. - IT Appeal No. 1054 of 2006 - - - Dated:- 15-3-2012 - N. Kumar and Ravi Mali .....

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..... chief of 'royalty' as defined under sub-clause [v] to Explanation 2 to Clause [vi] of section 9[1] of the Act." 3. Again in the case of CIT v. Samsung Electronics Co. Ltd. [2011] 203 Taxman 477/16 taxmann.com 141 (Kar.) the substantial question of law framed was as under: "The question which the High Court will answer is whether on facts and circumstances of the case, the ITAT was justif .....

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