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2023 (4) TMI 812 - AT - Income TaxTDS u/s 195 - Income taxable in India - licence fee - payment made by the assessee in the nature of Royalty under the provisions of the India Israel tax treaty and the same - Whether would be taxable in India at the rate of 10% of the gross amount of the royalties? - HELD THAT:- We find that the coordinate bench of the Tribunal in assessee’s own case in Celltick Mobile (India) Pvt. Ltd. [2021 (3) TMI 1121 - ITAT MUMBAI] allowed the appeal filed by the assessee and deleted similar addition made in the hands of the assessee for non-deduction of TDS while making the licence fees payment to Celltick Israel. Since a similar issue has been decided in Revenue’s appeal for the assessment year 2016-17, the decision rendered therein shall apply mutatis mutandis. As a result, grounds raised by the Revenue are dismissed.
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