Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2018 (10) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2018 (10) TMI 1939 - AT - Income TaxIncome deemed to accrue or arise in India - nature of the payments received from licensing of manufacturing and distribution rights of Microsoft Operations Pte Ltd - taxable as “royalty” under the provisions of Section 9(1)(vi) of the Act or not? - HELD THAT:- In the present case, it is noticed that the issue under consideration was also a subject matter of the assessee’s appeal for the assessment years 2007-08 to 2010-11 [2016 (9) TMI 1566 - ITAT DELHI] wherein we set aside the whole issue to the file of the assessing officer to decide it afresh in accordance with the decision of the Hon‘ble Delhi High Court in case of DIT V Infrasoft Limited [2013 (11) TMI 1382 - DELHI HIGH COURT] - Appeal of the assessee is allowed for statistical purposes.
|