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2020 (4) TMI 127 - AT - Income TaxIncome accrued in India - Royalty receipt or FTS - taxability of amount received by the assessee from Sandvik Asia Private Limited in India - HELD THAT:- It is an undisputed fact that during the year under consideration assessee had received fees towards granting user access to software application and for providing IT support from SAPL. Before us, both the parties have admitted that the facts of the case in the year under consideration are identical to that of assessee’s own case in A.Ys 2010-11, 2011-12, 2013-14 and 2014-15 [2019 (5) TMI 939 - ITAT PUNE]. We find that the Co-ordinate Bench of the Tribunal while deciding the issue on identical facts in assessee’s own case in A.Y. 2014-15 held that the payments received by assessee from SAPL cannot be considered to be as Royalty or FTS and not taxable in India. - Decided against revenue.
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