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2021 (9) TMI 1542 - HC - Income TaxTDS u/s 195 - Royalty - amounts paid by the concerned persons resident in India to non-resident, foreign software suppliers - Whether constitutes as taxable income deemed to accrue in India u/s 9(1)(vi) - income deemed to accrue or arise in India - HELD THAT:- As assessee submits that the substantial questions of law raised herein are squarely covered in the case of Engineering Analysis Centre of Excellence Private Limited [2021 (3) TMI 138 - SUPREME COURT] Revenue could not dispute the same.In view of the aforesaid submissions, the substantial questions of law are answered in favour of the assessee and against the revenue.
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