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1. Income accrued in India - consideration received by the assessee for sale of software cannot be treated as royalty under the provision of section 9(1)(vi) of the Act as...

2. Income deemed to accrue or arise in India - Royalty receipt - there was no transfer of copyright in the ‘off the shelf’ sale software; the consideration received thereby...

3. Income from sale of shrink wrap software - consideration received by the Assessee for software was not royalty. The receipts would constitute business receipts in the...

4. Sale of software as part of machinery - amount of sales consideration received by the assessee on account of sale of machine along with it operating software would not...

5. Taxability of receipt from sale of 'off-the shelf' software as 'Royalty' - India-Finland Tax Treaty - amount received by the assessee from its distributor for sale of...

6. Taxation of software reimbursements as Royalty - assessee strongly contends that reimbursements sought by the assessee represent recovery of expenses incurred by it, on...

7. Undisclosed incomes - investment in Purchase/sale of immovable property - The onus on the department to prove that investment was made by Assessees or sale consideration...

8. Additions of benefits or perquisites received as business income - waiver of loan u/s 28(iv) - the assessee had purchased the equipment, for which assessee had not paid....

9. TDS u/s 195 - payment for time charter higher charges are Royalty u/s 9(1)(vi) - The Tribunal held that the payments made by Jaisu Shipping Co. Pvt. Ltd. for hiring...

10. Royalty receipts - income deemed to accrue or arise in India - assessee had sold software licenses to its associated enterprises and to other Indian customers - The ITAT...

11. TDS u/s 195 - amounts paid by the assessee to the non-resident computer software manufacturers / suppliers as consideration for the resale / use of computer software, is...

12. Taxability of income in India - income from the sale of Software licenses subscription - India - Japan DTAA - CIT(A) held that the consideration received by the assessee...

13. Nature of receipt - sales tax remission benefit derived by the assessee - All the judgments cited before us also lay down the same ratio. Even otherwise subsidy is...

14. Nature of activity - sale or service - The appellant procured COA/stickers/labels under a Microsoft OEM Customer License Agreement, affixing them to Thin Clients...

15. Income accrued in India - royalty receipts - what is sold is the copyrighted software which is shrink-wrapped - the consideration received on the sale of off-the-shelf,...