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2018 (8) TMI 856 - AT - Income TaxTaxability of income of the appellant - permanent establishment (“PE”) in India - Royalty - supply of software - taxability of entire receipts from supply of software under section 44D read with section 115(l)(b)(A) of the Act - attribution of profit - Held that:- since it has already been held in the hands of Reliance Communications [2018 (4) TMI 80 - ITAT MUMBAI] by the elaborate order referred above that the payment made by it was not royalty in the hands of the assessee, these amounts are not taxable as income in the hands of the assessee. The issue that there is no PE in India has also been decided by the Tribunal in its order [2013 (9) TMI 374 - ITAT MUMBAI] Decided in favor of assessee.
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