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2023 (2) TMI 1303 - DELHI HIGH COURTTaxability of income India - Royalty receipts - income earned from licensing/sale of software - subscription receipts against cloud services offered by the respondent/assessee - Tribunal has ruled that neither income earned from licensing/sale of software products nor subscription fee earned for providing cloud services, could be construed as royalty - revenue, says that the proposed questions are covered by the judgment of Engineering Analysis Centre of Excellence (P.) Ltd. [2021 (3) TMI 138 - SUPREME COURT] HELD THAT:- We are as informed by Appellant that a review petition has been filed which is pending consideration. Accordingly, the appeal is closed as no substantial question of law arises for our consideration albeit, with the caveat that in case the appellant/revenue were to succeed in the review petition, parties will abide by the decision rendered therein.
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