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2012 (3) TMI 538 - AT - Income TaxTds u/s 195 - whether the payment of USD 58,000 payable to Verisity Design Inc, USA, for purchase of software was in the nature of royalty and the assessee was required to deduct tax at source and pay the same to the Government? - Held that:- Payment made by the assessee to non-resident companies would amount to royalty within the meaning of Article 12 of the DTAA with the respective countries and there was obligation on the part of the assessee to deduct tax at source u/s. 195 of the I.T. Act. We therefore do not see any infirmity in the order of the ld. CIT(A), as such we do not find any merit in this appeal of the assessee.
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