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2023 (10) TMI 259 - AT - Income TaxIncome accrued in India - royalty receipts - receipts towards software license and maintenance charges, global technology charges and GWAN connectivity charges - HELD THAT:- As we observe that the issues have been decided by Ld.CIT(A) in favour of the assessee following the decision of in assessee’s own case [2021 (12) TMI 571 - DELHI HIGH COURT] and also Engineering Analysis Centre of Excellence Pvt. Ltd. [2021 (3) TMI 138 - SUPREME COURT] and therefore, we see no infirmity in the order passed by the Ld.CIT(A) in holding that receipts towards software license and maintenance charges, global technology charges and GWAN connectivity charges are not royalty under the IT Act and also under India UK DTAA. Thus, we sustain the order of the Ld.CIT(A) and reject the grounds raised by the Revenue.
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