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2022 (11) TMI 1342 - AT - Income TaxIncome taxable in India - Royalty receipts - receipts on account of I.T. support services and management services - HELD THAT:- As decided in assessee own case [2022 (6) TMI 1382 - ITAT PUNE] extant payment received by the assessee can neither be considered as royalty u/s 9(1)(vi) of the Act nor as fees for technical services and therefore, the same cannot be included in the total income of the assessee. As in assessee’s own case, Pune Tribunal has given relief to the assessee on this very issue in A.Y. 2011-12 as well as in A.Y. 2017-18. The ld. CIT DR could not produce any materials/evidences on record to suggest any deviance from the facts situation. Therefore, following our order in assessee’s own case (supra) on the same parity of reasoning these grounds of the assessee are allowed.
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