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2023 (7) TMI 1001 - SCH - Income TaxIncome taxable in India - Addition of recharacterization of receipts from sale of software licenses to Indian customers/distributors as royalty - Whether taxing the same receipts in hands of Respondent would result in double taxation? - HELD THAT:- As we opine that the judgment of three judge Bench of this Court in Engineering Analysis Centre of Excellence Private Limited vs. Commissioner of Income Tax and Anr. [2021 (3) TMI 138 - SUPREME COURT] is holding the field and therefore, the said judgment would have to be followed in the instant case also. In view of the above, the Special Leave Petitions stand dismissed.
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