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2018 (6) TMI 1508 - AT - Income TaxTaxability of the amount received for supply of software as royalty - Held that:- We hold that the amount received by the assessee not being in the nature of royalty as per Article–12 of the India–Israel DTAA is not taxable as such in India, but, has to be treated as business profit of the assessee. Dependent agent PE in India - Held that:- We hold that TTI India cannot be treated as assessee’s dependent agent PE in India, hence, the amount is not taxable at the hands of the assessee. The grounds are allowed. The amount received by the assessee from supply of software to Reliance Communication Ltd. and Indus Towers Ltd. are not in the nature of royalty, this ground becomes redundant
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