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Halliburton Export Inc. C/o Nangia & Co. Chartered Accounts Versus Addl. DIT, Range-1, International Taxation, New Delhi

2015 (10) TMI 2513 - ITAT DELHI

Sale of software and maintenance services Payments to be taxable as Royalty u/s 9(1)(vi) of the Act Article 12 of DTAA between India and US - Held that:- Even though there is amendment to the Finance Act, 2012, there is no change in the DTAA betw .....

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or the right to use copyright but a limited right to use the copyrighted material and does not give rise to any royalty income - The consideration received on grant of licences for use of software is not royalty within the meaning of Article 12(3) of .....

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ssee. - I.T.A .No. 6273/Del/2012, I.T.A .No. 690/Del/2014 - Dated:- 23-10-2015 - R. S. Syal (Accountant Member) And Suchitra Kamble (Judicial Member) For the Appellant : Amit Arora (CA), Suraj Nangia (CA) For the Respondent : Anuj Arora, CIT DR ORDER .....

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14 passed by the ITAT, Delhi Bench). The same is taken on record and perused. The Hon ble Delhi High Court vide EITA 477/2014 (order dated 01.09.2014) has also confirmed the same. 2. However, the DR submitted that there is retrospective amendment and .....

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om 162 and submitted that the assessee s case is similar to the decision of Karnataka High Court. 3. By going through the order dated 14th February 2014 for A. Y 2008-09 in assessee s own case which is confirmed by the Delhi High Court, it is found t .....

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