2021 (9) TMI 1542 - HC - Income Tax

TDS u/s 195 - Royalty - amounts paid by the concerned persons resident in India to non-resident foreign software suppliers - Whether constitutes as taxable income deemed to accrue in India u/s 9(1)(vi) - income deemed to accrue or arise in India - HELD THAT - As assessee submits that the substantial questions of law raised herein are squarely covered in the case of Engineering Analysis Centre of Excellence Private Limited 2021 (3) TMI 138 - SUPREME COURT Revenue could not dispute the same.In view of the aforesaid submissions the substantial questions of law are answered in favour of the assessee and against the revenue.

Summary

The Karnataka High Court ruled in favor of the appellant (assessee) citing a precedent from the Supreme Court. The substantial questions of law raised were resolved in favor of the assessee, and the appeal was disposed of accordingly.