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2023 (7) TMI 1412 - ITAT DELHIRoyalty receipts - payments received for Telecommunication connectivity services - right to use of an equipment and/or use of a process and/ or transfer of rights in a process and/ or imparting of any information - Addition u/s 9(1)(vi) of the Income Tax Act, 1961 and under the Article 12(3) of the India Singapore Tax Treaty (Tax Treaty') - assessee is a company incorporated in Singapore - HELD THAT:-The Co-ordinate Bench of ITAT Delhi in assessee's own case for AY 2015-16 and 2016-17 in [2022 (7) TMI 1514 - ITAT DELHI] and for A.Y. 2011-12, 2012-13 and A.Y. 2014-15 [2020 (10) TMI 604 - ITAT DELHI] and noted that the controversy regarding amendment in the Act being read into the treaty has been settled in the case of Engineering Analysis Centre of Excellence Private Limited [2021 (3) TMI 138 - SUPREME COURT] Thus we allow the grounds of appeal raised by the assessee and direct the AO to delete the additions made on account of "Royalty - Decided in favour of assessee.
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