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2020 (7) TMI 97 - AT - Income TaxTreating the sale receipts of shrink-wrap software as ‘royalty’ - 'sale of copyrighted article' OR 'transfer of copyright right' - whether nature of royalty under the provisions of section 9(l)(vi) of the Act as well as Article 12(3) of the Double Taxation Avoidance Agreement ("DTAA") between India and USA? - HELD THAT:- As decided in own case [2020 (1) TMI 611 - ITAT MUMBAI] we herein conclude that the addition made by the A.O by treating the sale receipts of shrink-wrap software as ‘royalty’ cannot be sustained, and is hereby vacated. - Decided in favour of assessee.
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