2012 (2) TMI 696

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..... , 1. The revenue has preferred this appeal against the order passed by the Tribunal which has granted relief to the assessee. 2. In fact, the substantial question of law which arises for consideration in this appeal arose for consideration before this court in two appeals, firstly in the case of Commissioner of Income tax And Another v Synopsis international Old Ltd., in ITA Nos. 11 to 15/2 .....

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..... n holding that the amount[s] paid by the appellant s t0 the foreign software suppliers was not 'royalty and that the same did not give rise to any 'income' taxable in India and. therefore, the appellants was not liable to deduct any tax at source? 4. In both the cases, it was held that consideration paid by the Indian customers end users to the assessee a foreign supplier, for tran .....

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